SEC v. Richard M. Kirsch and Adam Terris (insider trading, 2020)

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.

Report an error in this record (sec-richard-m-kirsch-insider-trading-2020) by email

In September 2020 the SEC charged two former PetMed Express executives, Richard Kirsch and Adam Terris, with insider trading in PetMed securities; both consented to injunctions and five-year officer-and-director bars. Kirsch agreed to a $1,057,392 penalty and Terris to $1,454,800.

The record

What was ordered

Civil penalty

$2.5m

Disgorgement

—

Prejudgment interest

—

Total relief

$2.5m

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 settled complaint on September 10, 2020 as litigation release 24892, filed in the Southern District of Florida.

The complaint alleges Kirsch traded PetMed stock and call options before seven earnings announcements between December 2014 and January 2018, for gains and avoided losses of $164,966, and in March 2017 bought options with money Terris supplied and gave Terris the $727,400 profit.

Without admitting or denying the allegations, both consented to injunctions under Section 10(b) and Rule 10b-5. The stored penalty of $2,512,192 is the sum of both respondents' penalties; the record earlier showed only Kirsch's.

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. 2020-09-10 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.