At the time of Spaugy's trading, SemGroup was SGLP's parent company and its largest source of revenue. According to the Commission's complaint, between late May 2008 and the morning of July 15, 2008, and in the course of his employment at SemGroup, Spaugy learned that SemGroup was in a liquidity crisis. The complaint further alleges that from July 15 and 16, 2008, while in possession of this material, non-public information, Spaugy sold 4,500 SGLP units, which were then traded on Nasdaq, at an average price of $23.28 per unit. On July 17, SGLP publicly announced that SemGroup was experiencing liquidity issues and considering bankruptcy, causing the price of its units to drop well below Spaugy's average sale price. By secretly trading on nonpublic information, Spaugy breached a duty of trust and confidence he owed to SemGroup and avoided losses of $67,424. [SEC v. Don N. Spaugy, Civ. Action No. 09-CV-687-TCK-FHM (United States District Court for the Northern District of Oklahoma)] (LR-21260)

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