Former SEC Enforcement Attorney · 9 Years, SEC Division of Enforcement
SECFederal court2000

SEC v. American Imaging, Inc., et al.

No. 00-0940-CIV-MORENO (S.D. Fla. 2000)

Matter at a glance

Year
2000
Agency
U.S. Securities and Exchange Commission
Forum
Federal court
Mr. Lehrer's role
Staff attorney
Docket / file
No. 00-0940-CIV-MORENO (S.D. Fla. 2000)

What the matter involved

Fraudulent revenue and net income projections issued by an internet company.

The matter was brought by the U.S. Securities and Exchange Commission and heard as a federal court. Mr. Lehrer worked the file as a staff attorney, which meant building the record on the government's side — the documents, the testimony, and the theory of the violation — rather than responding to it.

  • Issuer fraud. Issuer fraud cases turn on what the company told the market versus what its own records showed. Investigators start with the public statement and work backwards through board minutes, internal projections, and bank records.
  • Financial projections. Forward-looking numbers are not automatically protected. Projections become actionable when there is no reasonable basis for them at the time they are published.

Outcome and public record

This matter was resolved on the public record of the U.S. Securities and Exchange Commission under No. 00-0940-CIV-MORENO (S.D. Fla. 2000). Out of respect for the individuals and entities named, this page does not restate penalties, bars, or sentences. The agency's own release for the matter is the authoritative record of its disposition.

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Past results in government enforcement matters do not predict or guarantee the result of any future matter. This page describes work performed on behalf of a government agency before Mr. Lehrer entered private practice in 2000.

Why this matters to issuers today

The staff still builds files the same way: start with the public document, test it against the company's own records, and interview the people who signed. Knowing how that record gets assembled is the reason issuers bring this experience in at the drafting stage — before a filing, an offering, or a promotion creates the paper trail a later investigation would follow.

Questions about a filing, an offering, or a promotion?

Talk directly to a former SEC enforcement attorney — no intake staff, no forms.

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