SEC Complaint: Lawrence J. Robbins - MemoFin.fr

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placed from Allen's cell phone to Bennett's cell phone, followed by two additional phonecalls between Allen and Bennett, at 8:56pm and 8:57pm. Later that night, at 10:01 pm,there was a 26-minute phone call between Bennett and Robbins.24. Similarly, on February 28, 2008, Allen sent an email to a colleagueindicating that Takeda "raised the tender offer price to $25." That day, Allen travelledfrom New York to Atlanta, and, at 10:13 pm, there was a phone call placed from Allen'shome number (in Atlanta) to Bennett's cell phone lasting approximately nine minutes.Shortly after ending his call with Allen, Bennett called Robbins's cell phone from his cellphone. This call lasted approximately three minutes.25. Allen tipped Bennett with inside information regarding Takeda'simpending acquisition of Millennium. In doing so, Allen misappropriated the insideinformation from his employer, and his employer's client, Takeda, concerning Takeda'splans to acquire Millennium.26. Bennett, in turn, tipped Robbins with inside information regardingTakeda's impending acquisition of Millennium on or before February 28, 2008. DuringFebruary and March 2008, Bennett and Robbins maintained an office in MidtownManhattan, and worked in the same room. In addition to working in close physicalproximity, during this timeframe, Bennett and Robbins often spoke by telephone multipletimes a day.27. As detailed further below, after receiving this information, both Bennettand Robbins traded Millennium securities, including purchasing more than 3,400 out-ofthe-moneycall options.8
Bennett's Millennium Securities Transactions28. Bennett traded on the basis of the inside information provided by Allen bypurchasing Millennium call options in an account he held jointly with his wife at TDAmeritrade. Between February 29 and April2, Bennett invested over $17,100 topurchase 1,090 out-of-the-money Millennium call options.29. Bennett maintained communication with Allen while purchasing theseMillennium securities. For example, Bennett and Allen had telephone calls on the firstthree days that Bennett purchased Millennium call options: Friday, February 29, 2008;Monday, March 3, 2008; and Wednesday, March 5, 2008.Robbins's Millennium Securities Transactions30. Robbins learned the inside information concerning Millennium fromBennett and traded on the basis ofit beginning on February 28, 2008.31. In an account at E*Trade, Robbins purchased a total of700 shares ofMillennium stock on Thursday, February 28 (500 shares) and Friday, February 29 (200shares), with an average price of$14.32 per share. In an account at Merrill Lynch,Robbins purchased a total of2,351 out-of-the-money call options between Friday,February 29, 2008 and Thursday, March 6, 2008. Specifically, Robbins purchased: (i)125 May $17.50 call options and 75 May $15 call options on Friday, February 29; (ii)1,100 May $20 call options on Monday, March 3; (iii) 751 May $20 call options onWednesday, March 5, 2008; and (iv) 300 May $20 call options on Thursday, March 6,2008.32. All of the call options Robbins purchased had a strike price aboveMillennium's share price, which never closed at a price above $14.11 between February9
Page 1 and 2: Sanjay WadhwaAttorney for Plaintiff
Page 3 and 4: JURISDICTION AND VENUE 4. This Cour
Page 5 and 6: expected to rise, or sells a call w
Page 7: nonpublic written offer to buy Mill
Page 11 and 12: markets, by issuing a joint press r
Page 13 and 14: Bennett 's Sepracor Securities Tran
Page 15 and 16: profits from his Sepracor investmen
Page 17 and 18: 64. The operating agreement for the
Page 19 and 20: een taken, Robbins purchased securi

SEC Complaint: Lawrence J. Robbins - MemoFin.fr

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