SEC v. David E. Zilkha (insider trading, 2011)

Judgment entered

✓ Checked against the primary document on October 2, 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-david-e-zilkha-insider-trading-2011) by email

In April 2011 an SEC administrative law judge found that David Zilkha, then at hedge fund adviser Pequot, passed material non-public information about Microsoft to Pequot's chief executive, who traded on it in April 2001. The judge ordered a cease-and-desist and $250,000 disgorgement plus interest.

The record

What was ordered

Civil penalty

—

Disgorgement

$250k

Prejudgment interest

—

Total relief

$250k

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 published the initial decision on April 13, 2011 (administrative proceeding 3-13913).

The decision finds Zilkha willfully violated Exchange Act Section 10(b) and Rule 10b-5 by giving Arthur Samberg information about Microsoft he held as a Microsoft insider. Samberg and Pequot had settled earlier.

The Division had asked for $2,523,000 in disgorgement, a $120,000 penalty and industry bars; the judge ordered only a cease-and-desist and $250,000 disgorgement with interest. The earlier record showed the Division's requests as the outcome and the matter as settled.

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. 2011-04-13 Initial decision

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• Initial decision (ID-415)
• Finality order

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.