0433-2019 Mr. A. Kumar vs Securities and Exchange Board of India
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the SEC's efforts to deter others from violating the securities laws, but disgorgement may not be used punitively. See SEC v. Blatt, 583 F.2d 1325, 1335 (5th Cir.1978); SEC v. Manor Nursing Centers, Inc., 458... Although the SEC bears the ultimate burden of persuasion that its disgorgement figure reasonably approximates the amount of unjust enrichment, we believe the government's showing of appellants' actual profits on the tainted transactions at least presumptively satisfied that burden. Appellants, to whom the burden of going forward shifted, were then obliged clearly to demon
BEFORE THE SECURITIES APPELLATE TRIBUNAL
MUMBAI
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