SEC v. Nathaniel Brown, Benjamin Wylam, Naveen Sood, Marcus Bannon, Matthew Rauch, and Naresh Ramaiya (insider trading, 2021)

Settled

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In June 2021 the SEC charged six people in a Silicon Valley ring that traded on tipped earnings information from Infinera and Fortinet for nearly $1.7 million. Four of them consented to judgments with penalties totalling $653,827, one agreed to an injunction with penalties to be set, and the case against the Infinera source continues.

The record

What was ordered

Civil penalty

$654k

Disgorgement

—

Prejudgment interest

—

Total relief

$654k

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 the case on June 25, 2021 as litigation release 25123; the complaint was filed on June 15 in the Northern District of California.

The complaint alleges Nathaniel Brown tipped his friend Benjamin Wylam about Infinera's earnings, that Wylam traded and tipped Naveen Sood, and that Sood passed it to Marcus Bannon, Matthew Rauch and Naresh Ramaiya, with Bannon also supplying Fortinet information.

Bannon agreed to a $281,497 penalty, Rauch $128,230, Ramaiya $65,780 and Sood $178,320, all subject to court approval; Wylam consented to an injunction with penalties to be decided. The earlier record listed the status as judgment and showed only Bannon's penalty, with the names run together.

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 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. 2021-06-25 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.

• SEC litigation release

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.