KRM Services, LLC – Complaint Filed by SEC | Goodman & Nekvasil P.A. May Recover Investor Losses
According to the SEC Allegations
KRM is a Florida limited liability company incorporated by Roberto J. Clark, Jr. During the time period at issue, KRM had a principal place of business in Arlington, Virginia and Chevy Chase, Maryland.
Roberto Clark was KRM’s founder, manager, and majority owner during the time period at issue. At all relevant times, Clark controlled KRM. Clark offered and sold securities to investors from KRM’s places of business in Maryland and Virginia. The majority of Clark’s securities solicitations were conducted in Alexandria and Fairfax, Virginia.
From December 2016 to approximately February 2019, Roberto Clark engaged in a fraudulent scheme to solicit individuals to make short-term loans to KRM, a company that Roberto Clark controlled, and to invest in unregistered securities issued by KRM. Roberto Clark claimed that KRM needed funds to market and develop its “JetBoard,” a motorized surfboard, and that KRM already had pending orders for the surfboard. In fact, KRM had no orders or contracts for any products and Clark diverted most of the approximately $350,000 that he obtained from multiple investors to his personal use.
In furtherance of the scheme, Clark offered unregistered securities, made material misrepresentations about KRM’s business, provided investors with fabricated purchase orders, and engaged in other deceptive acts to convince prospective investors that KRM had income from which KRM could repay the loans.
Defendants’ misappropriation, materially false statements, and related deceptive acts violated the antifraud provisions of the Securities Act of 1933 (“Securities Act”), 15 U.S.C. § 77q(a), and the Securities and Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. § 78j(b), as well as the registration provisions of the Securities Act, 15 U.S.C. § 77e(a) and (c). The Commission respectfully requests, among other things, that the Court enjoin Clark and KRM from committing further violations of the federal securities laws as alleged in this Complaint; issue a conduct-based injunction prohibiting Defendants from participating in the issuance, offer, or sale of any security; and order Defendants to pay disgorgement, plus pre-judgment interest, and monetary penalties based upon these violations.
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