The US Department of "Justice" has charged a Chinese man, Micheal Yin of Beijing, with 14 felony charges of securities fraud in the Southern District of New York. Yin is alleged to have traded shares of Lattice Semiconductor using non-public information. A second man, Benjamin Chow who worked for a private equity firm in Palo Alto is alleged to be the source of the information following Chow's own guilty plea. The full text is below:
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STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
MICHAEL ,
a/ k/ a "Shaohua Y in, "
Defendant .
Case 1:18-cr-00494-JGK
1.
Document 1
Filed 07/16/18
Page 1 of 21
ORIGINAL
INDICTMENT
94
x
COUNT ONE
FILED
6 2018
Fraud)
(Conspiracy to Commit Securities
The Grand Jury charges :
Relevant Individuals and Enti ties
At all times relevant to this Indictment, MICHAEL YIN ,
a/ k/ a "Shaohua Y in," the defendant, was a partner at a long/ short
equity investment firm based in Hong Kong .
YIN control led and
used at least five brokerage accounts maintained with a brokerage
firm in the United States to conduct personal securities trading
The Nominee Accounts were held in the
( the "Nominee Accounts" )
names of close relatives and other associates of YIN.
2.
At all times relevant to this Indictment, Firm-I was a
private equity investment firm headquartered in Beij ing, China.
3.
At all times relevant to this Indictment, Firm-2 was a
private equity investment firm headquartered in Palo Alto,
California, with offices in Beij ing, China.****** Result for Image/Page 2 ******
From in or about February 2016 to in or about
2016, Benj amin Chow, a co-coconspirator not named as a
In or about
herein, was the Managing Director of Firm-I .
Case 1:18-cr-00494-JGK Documenti Filed 07/16/18 Page 2 of 21
4.
6.
September
de f endant
September
2016, Chow and others founded Firm-2 and Chow became the Managing
Partner of Firm-2.
5.
At all times relevant to this Indictment, Lattice
( "Lattice" ) was a publicly traded
Semiconductor Corporat ion
technology company headquartered in Portland, Oregon. Lattice' s
shares traded under the symbol "LSCC" on the Nasdaq Stock Market ,
which is located in Manhattan, New York. Among other products,
Lattice specialized in developing and manufacturing field-
programmable gate arrays ( "FPGAs") , which are integrated circuits
designed to be configured by a customer or a designer after
manufacturing .
Overview of the Insider Trading Scheme
From at least in or about March 2016 through in or about
February 2017, MICHAEL Y IN, a/ k/ a "Shaohua Yin, " the defendant,
made profitable securities trades in Lattice stock based upon
material non-public information relating to a potential merger
between Lattice and Firm-I and later, Firm-2 , which was provided
to YIN by Benj amin Chow in violation of Chow' s duties to Lattice .
Specifically :
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As Managing Director of Firm-I and then Managing
a.
Partner of Firm-2, Chow obtained material non-public information
regarding a potential merger agreement between Lattice and Firm-I
Information concerning the
and later , Lattice and Firm-2.
potential merger agreement, including the fact that the parties
were exploring the possibility of a merger, was subject, among
other things, to nondisclosure agreements executed between Lattice
Chow signed
and Firm-I and later, between Lattice and Firm-2 .
each of these nondisclosure agreements on behalf of Firm-I and
Firm-2 .
In violation of these nondisclosure agreements ,
Chow provided YIN with material non-public information regarding
the potential merger between Lattice and Firm-I and later, Firm-
2.
On numerous occasions, YIN used the material non-
c.
public information provided by Chow to make profitable trades in
Lattice stock, yielding a total of approximately $5 million in
profits .
Chow' s Confidentiality Obligations
7 . On or about April 27, 2016, Benj amin Chow signed, as
Managing Director of Firm-I, a nondisclosure agreement between
Lattice and Firm-I relating to a potential merger between the
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The Lattice/ Firm- 1 NDA
parties (the "Lattice/ Firm—I NDA" ) .
provided, among other things, that " [t] he fact of the exploration
and evaluation of a potential strategic relationship between the
and subj ect to the
parties shall be deemed 'Conf idential '
The
protections of this Agreement as Proprietary Information . "
Lattice/ Firm-I NDA further provided that such Proprietary
Information may not be disclosed or used "for any purpose, except
and
to evaluate and/or engage in discussions regarding ,
potentially pursue and effect, the potential business transaction
involving the parties . "
8 . On or about September 9, 2016, shortly after Benj amin
Chow formed Firm-2i Chow signed, as Managing Partner of Firm-2, a
nondisclosure agreement between Lattice and Firm-2 relating to a
potential merger between the parties (the "Lattice/ Firm-2 NDA") .
The Lattice/ Firm-2 NDA imposed the same obligations on Chow as
were imposed on him in the Lattice Firm-I NDA.
YIN' s Relationship With Chow
MICHAEL Y IN, a/ k/ a "Shaohua Y in, " the defendant, and
9.
Benj amin Chow had both previously worked at the same private equity
where they focused on investments in the
inves tment firm,
technology, media and telecommunications sector .
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In or about March 2016, MICHAEL Y IN, a/k/a "Shaohua Y in, "
10.
the defendant, sent a text message to Benj amin Chow, telling Chow
that YIN was operating his own investment fund focused on
long/short equity positions; in essence, that YIN was a full-time
Against that backdrop, in the following months YIN and
träder .
Chow met on multiple occasions for coffee and exchanged text and
voice messages .
YIN Purchases Millions of Shares of Lattice After Receiving
Material Non-Pub1ic Information From Chow
Relating to the Lattice Merger
11. Beginning in or about April 2016 , Benj amin Chow
participated as Managing Director of Firm-I in discussions with
representatives of Lattice relating to a potential offer by Firm-
1 to acquire Lattice. On or about April 27, 2016, Chow signed the
Lattice/ Firm-I NDA on behalf of Firm-I.
12. on or about July 5, 2016, MICHAEL YIN, a/k/a "Shaohua
Y in, " the defendant, and Benjamin Chow arranged via text message
to meet that same day at a coffee shop in the China World Trade
Center located in Beij ing, China. Later that night, YIN purchased
a total of approximately 248, 268 shares of Lattice .
13. On or about July 7 , 2016, Firm-I submitted a confidential
non-binding indication of interest to Lattice, proposing to
acquire all outstanding shares of Lattice for $8 . 00 per share in
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Based on the closing trading price of $5.32 for Lattice
cash .
2016, the
common shares on the previous trading day, July 6 ,
Firm-I ' s July 7 ,
2016
proposal implied a premium of 50% .
submission contemplated that Firm-I and Lattice would approach the
Committee on Foreign Investment in the United States ("CFIUS" )
which is an inter-agency government committee authorized to review
transactions that could result in control of a United States
business by a foreign person .
14. On or about July 12, 2016, MICHAEL Y IN, a/ k/ a "Shaohua
" the defendant, exchanged text messages with Benj amin Chow
Y in,
relating to: Firm-I' s confidential indication of interest in
acquiring Lattice, F PGA technology, CPIUS, and the identity of the
law firm advising Firm-I on the proposed merger (the "Law Firm") .
Later on or about July 12, 2016, YIN and Chow agreed via text
message to meet the following day, July 13, 2016, at Chow's office
Beginning on or about July 13, 2016 through
in Beij ing, China .
2016 , YIN purchased a total of approximately 280 , 283
July 22,
shares of Lattice.
15. On or about July 28, 2016, Firm-I submitted to Lattice
a revised confidential non-binding indication of interest in
acquiring Lattice in an all-cash transaction for a price between
$8 .75 and $9.00 per share. Based on the closing trading price of
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$6 . 14 for Lattice common shares on the previous trading
proposal implied a premium of between 43% and . The
two business days, Friday, July 29, 2016 , and Monday,
2016, MICHAEL YIN, a/k/a "Shaohua Yin," the defendant,
a total of approximately 150, 000 shares of Lattice .
day, this
fol lowing
August 1
purchased
16. On or about August 10, 2016, Benj amin Chow sent a text
message to MICHAEL Y IN, a/ k/ a "Shaohua Y in, " the defendant, stating
and therefore could not
that he was "in the middle of a deal, "
leave the West Coast of the United States, which is where Lattice
The same day, YIN a total of
is headquartered.
approximately 120, 000 shares of Lattice.
2016 , Lattice notified Firm-I
17 . On or about August 17 ,
that it received an expression of interest from another party to
acquire Lattice, but that it had declined to meet with this other
party pursuant to Lattice' s obl igations under an exclusivity
agreement Lattice had entered into with Firm-I. Via text message,
MICHAEL Y IN, a/ k/ a "Shaohua Y in, the defendant, and Benj amin Chow
arranged to meet that same day. Later that day, YIN purchased a
total of approximately 35, 800 shares of Lattice .
In or about early September 2016, Benj amin Chow formed
18.
a new private equity firm, which ultimately became Firm-2 .
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19. On or about September 9 , 2016, Benjamin Chow signed the
Lattice/Firm-2 NDA. That same day, MICHAEL YIN, a/k/a "Shaohua
" the defendant, purchased a total of approximately 44, 554
Yin,
shares of Lattice. The following day, September 10, 2016, Firm-2
submitted to Lattice a conf idential non-binding indication of
interest to acquire Lattice for $8 .30 per share in an all-cash
transaction. Based on the closing trading price of $5 . 98 for
Lattice common shares on the previous trading day, the proposal
implied a premium of .
2016 , Lattice and Firm-2
On or about September 13 ,
20.
entered into an exclusivity agreement, providing that Lattice
would not initiate discussions regarding a potential acquisition
with any third party through at least October 4 , 2016. Also on or
about September 13, 2016, the Law Firm, now acting as counsel to
Firm-2, provided Lattice' s counsel with a draft merger agreement .
Also on or about September 13, 2016, MICHAEL YIN, a/k/a "Shaohua
the defendant, and Benj amin Chow arranged to meet at a
Y in, "
particular time that same day at the China World Trade Center in
Beij ing, China. Later on the same day, YIN purchased approximately
116, 387 shares of Lattice. The following day, September 14, 2016,
YIN purchased approximately 260, 501 shares of Lattice. On or about
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September 15, 2016, the following day, YIN purchased an additional
approximately 536, 310 shares of Lattice .
2016,
21 . On or about September 16 ,
the defendant, sent a text
"Shaohua Y in, "
MICHAEL YIN, a/k/a
mes sage to another
individual stating, in substance and in part (in translation)
that a "friend" had told YIN that the Lattice merger was moving
That same day, YIN purchased a total of approximately
forward .
208, 300 shares of Lattice.
2016, MICHAEL YIN, a/k/a
22 . On or about September 21 ,
"Shaohua Y in, " the defendant, sent a voice message to Benj amin
Chow relating to the potential merger between Lattice and Firm-2.
In this message, YIN related, in substance, that YIN had heard
from a banker that Lattice was concerned about obtaining CFIUS
Chow responded by voice
approval for the merger with Firm-2.
message that same day, September 21, 2016, stating (in translation)
that "we should be able to sign the contract soon. Yeah. "
Beginning the following day, through and including October 12 ,
2016, YIN purchased approximately 2, 206, 760 shares of Lattice .
on or about October 17, 2016, MICHAEL YIN, a/k/a "Shaohua
23.
Y in, " the defendant, and Benj amin Chow arranged via text message
to meet that day at the China World Trade Center in Beij ing, China.
Following the time set for this meeting, YIN sent text messages to
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two individuals advising them to purchase shares of Lattice .
To
in pertinent part (in
one of these individuals , YIN wrote ,
If not, purchase 5-10%
"Is your position loaded?
translation) ,
(not urgent, buy in batches over
[position] of LSCC at around $6 .
To the other, YIN wrote, in pertinent part (in
3-5 days) .
"Just buy 25, 000 shares of LSCC (Either change a
translation) ,
position, or use the remaining 1/3.) For the $150, 000 position, I
Also beginning the day of this
will bear the risk for you. "
meeting, October 17, 2016, through and including October 24, 2016 ,
YIN purchased a total of approximately 1, 931, 102 shares of Lattice .
On or about November 1, 2016, Lattice senior management
24 .
met with
agreement .
defendant ,
Lattice .
25.
representatives of Firm-2 and finalized the merger
That same day, MICHAEL YIN, a/k/a "Shaohua Yin," the
purchased a total of approximately 427 , 949 shares of
2016 , Lattice ' s board of
On or about November 2 ,
directors formally approved the transaction whereby Firm-2 would
purchase all shares of Lattice common stock for $8.30 per share.
" the de fendant ,
That same day, MICHAEL Y IN, a/ k/ a "Shaohua Y in,
purchased approximately 476 , 500 shares of Lattice .
26. The following day, November 3 , 2016, Firm-2 and Lattice
formally executed a merger agreement and issued a joint press
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release announcing the merger which noted, among other things ,
that the $8 . 30 per share price represented a premium to
Lattice's last trade price on November 2, 2016, the last trading
day prior to announcement. The agreement was signed by Benj amin
Chow on behalf of Firm-2. The closing price of Lattice on November
3, 2016 was $7.55 per share, up approximately $1.18 per share from
the closing price the previous day .
27. on or about November 3, 2016, MICHAEL YIN, a/k/a "Shaohua
Y in," the defendant, sold a substantial quantity of the Lattice
shares he had purchased, resulting in a profit of approximately $5
mi 11 ion.
28 . The merger agreement between Lattice and Firm-2 was
expressly contingent upon CFIUS approving the merger, without
which the agreement would be dissolved and Firm-2 would have no
obligation to purchase Lattice shares for $8.30 per share .
From in or about November 2016 through in or about early
29.
" the defendant ,
February 2017, MICHAEL YIN, a/k/a "Shaohua Yin,
purchased approximately 2 , 143 , 447 additional shares of Lattice at
market prices which were below the merger price of $8.30 per share .
During this same period, YIN sought and received from Chow material
non-public information concerning the status of the CFIUS approval
process for the merger between Lattice and Firm-2 .
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30. On or about December 6 , 2016, MICHAEL YIN, a/ k/ a "Shaohua
sent a text message to Benj amin Chow
the def endant ,
Yin, "
referencing a news report that United States lawmakers had urged
rejection of the merger and asking "is it serious? Or just noise?"
Chow responded [h] appens all the time . "
31. on or about January 24, 2017, MICHAEL YIN, a/k/a "Shaohua
Y in," the defendant, sent a text message to Benjamin Chow, asking,
in substance and in part, whether (in translation) "that thing
later after you arrived in DC, was there. any
with you guys ,
progress?" Chow responded, in substance, that he expected CFIUS to
approve the merger in March. YIN then sent another text message
whether the new presidential
to Chow asking, in substance ,
administration would present a problem for obtaining CPIUS
approval. Chow replied ( in translation) "no. "
Statutory Allegations
From at least in or about March 2016 through in or about
32.
February 2017, in the Southern District of New York and elsewhere,
MICHAEL Y IN, a/ k/ a "Shaohua Y in, " the defendant, and others known
consp i re ,
willfully and knowingly did combine ,
and unknown ,
confederate and agree together and with each other to commit an
offense against the United States, to wit, securities fraud, in
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violation of Title 15, United States Code, Sections 78} (b) & 78ff,
and Title 17, Code of Federal Regulations, Section 240 . 10b-5.
It was a part and obj ect of the conspiracy that MICHAEL
33.
the defendant, and others known and
YIN , a/ k/ a "Shaohua Y in, "
unknown, willfully and knowingly, directly and indirectly, by the
use of means and instrumentalities of interstate commerce, and of
the mails, and of facilities of national securities exchanges ,
would and did use and employ, in connection with the purchase and
manipulat i ve and deceptive devices and
sale of securities ,
contrivances in violation of Title 17, Code of Federal Regulations,
section 240 . 10b-5 by: (a) employing devices, schemes and artifices
to defraud; (b) making untrue statements of material fact and
omitting to state material facts necessary in order to make the
statements made, in the light of the circumstances under which
they were made, not misleading; and (c) engaging in acts, practices
and courses of business which operated and would operate as a fraud
and deceit upon persons, in violation of Title 15, United States
Code, Sections 78 j (b) and 78ff.
illegal
Overt Acts
In furtherance of the conspiracy and to effect the
the
object thereof, MICHAEL YIN, a/k/a "Shaohua Yin, "
defendant, and others known and unknown, committed the following
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overt acts, among others, in the Southern District of New York and
elsewhere :
a.
On or about September 21, 2016, Benj amin Chow sent
a voice message to MICHAEL Y IN, a/k/a "Shaohua Y in, " the defendant ,
regarding a possible merger between Firm-2 and Lattice .
2 016 , YIN purchased a
On or about September 22 ,
total of approximately 417 , 015 shares of Lattice .
(Title 18, United States Code, Section 371. )
COUNTS TWO THROUGH THIRTEEN
(Securities Fraud)
The Grand Jury further charges :
35 . The allegations set forth in paragraphs 1 through 31 and
paragraph 34 are realleged and incorporated by reference as if
fully set forth herein.
36 . On or about the dates set forth below, in the Southern
District of New York and elsewhere, MICHAEL Y IN, a/ k/ a "Shaohua
the defendant , wi 11 fully and knowingly, directly and
Y in,
indirectly, by the use of means and instrumentalities of interstate
and of facilities of national
and of the mails ,
commerce ,
securities exchanges, used and employed, in connection with the
manipulative and decept i ve
purchase and sale of securities ,
devices and contrivances in violation of Title 17, Code of Federal
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Regulations, Section 240 .10b-5 by: (a) employing devices, schemes
and artifices to defraud; (b) making untrue statements of material
fact and omitting to state material facts necessary in order to
make the statements made, in the light of the circumstances under
which they were made, not misleading; and (c) engaging in acts ,
practices and courses of business which operated and would operate
as a fraud and deceit upon persons, to wit, YIN conducted the
securities transactions described below based upon material, non-
public information provided to YIN by Benjamin Chow regarding a
in
potential merger between Lattice and Firm-I and Firm-2 ,
violation of duties Chow owed to Lattice :
Count
2
3
4
5
6
8
Date (s)
July 5, 2016
July 13, 2016
through July 22 ,
2016
July 29, 2016 and
August 1, 2016
August 10,
August 17 ,
September
2016
2016
9, 2016
September 13, 2016
through September
15t 2016
15
Transaction
Purchase of
approximately 248 , 268
shares of Lattice
Purchase of
approximately 280 , 283
shares of Lattice
Purchase of
approximately 150 , 000
shares of Lattice
Purchase of
approximately 120 , 000
shares of Lattice
Purchase of
approximately 35, 800
shares of Lattice
Purchase of
approximately 44 , 554
shares of Lattice
Purchase of
approximately 913 , 198
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9
10
11
12
13
September 16 ,
September 22 ,
2016
2016
through October 12 ,
2016
October 17, 2016
through October 24 ,
2016
November 1,
November 2 ,
2016
2016
Purchase of
approximately 208, 300
shares of Lattice
Purchase of
approximately
2,206, 760 shares of
Lattice
Purchase of
approximately
I, 931, 102 shares of
Lattice
Purchase of
approximately 427 , 949
shares of Lattice
Purchase of
approximately 476 , 500
shares of Lattice
(Title 15, United States Codet Sections 78 j (b) & 78 f f;
Title 17, Code of Federal Regulations, Section 240 . 1 Ob-5; and
Title 18, United States Code, Section 2 . )
COUNT FOURTEEN
(Securi ties Fraud)
The Grand Jury further charges :
37. The allegations set forth in paragraphs 1 through 31 and
paragraph 34 are realleged and incorporated by reference as if
fully set forth herein.
From at least in or about March 2016 through in or about
38.
February 2017, in the Southern District of New York and elsewhere ,
the defendant, willfully and
MICHAEL YIN, a/k/a "Shaohua Yin, "
knowingly executed a scheme and artifice to (a) defraud persons in
connection with securities of an issuer with a class of securities
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registered under Section 12 of the Securities Exchange Act of 1934
and that was required to file reports under Section 15 (d) of the
Securities Exchange Act of 1934, and (b) obtain, by means of false
and fraudulent pretenses, representations, and promises, money and
property in connection with the purchase and sale of securities of
an issuer with a class of securities registered under Section 12
of the Securities Exchange Act of 1934 and that was required to
file reports under Section 15 (d) of the Securities Exchange Act of
1934, to wit, YIN traded in Lattice stock based upon material ,
non-public information provided to YIN by Benj amin Chow regarding
in
a potential merger between Lattice and Firm-I and Firm-2 ,
violation of duties Chow owed to Lattice .
(Title 18, United States Code, Sections 1348 & 2.)
FORFEITURE ALLEGATION
39. As a result of committing the offenses alleged in Counts
One through Fourteen of this Indictment, MICHAEL Y IN, a/ k/ a
"Shaohua Y in," the defendant, shall forfeit to the United States,
pursuant to Title 18, United States Code, Section 981 (a) (1) (C) and
Title 28, United States Code, Section 2461 (c) , any and all
property, real and personal, that constitutes or is derived from
proceeds traceable to the commission of said offenses, including
but not limited to a sum of money in United States currency
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representing the amount of proceeds traceable to the commission of
said offenses and the following specific property:
a. A sum of $1, 743, 626 .83 held at Interactive Brokers, LLC
in an account with the last four digits 9828 in the name
representing the net proceeds from the sale
"Lizhao Su, "
of Lattice shares on or about November 3, 2016 in this
account ;
b. A sum of $238, 387.55 held at Interactive Brokers, LLC
in an account with the last four digits 1566 in the name
representing the net proceeds from the sale
"Yan Zhou, "
of Lattice shares on or about November 3, 2016 in this
account ;
c. A sum of $816, 872 . 14 held at Interactive Brokers, LLC in
an account with the last four digits 8920 in the name
representing the net proceeds from the sale
"Jun Qin,"
of Lattice shares on or about November 3, 2016 in this
account ;
d. A sum of $2, 144, 110.09 held at Interactive Brokers, LLC
in an account with the last four digits 9198 in the name
represent ing the net proceeds from the
"Zhiqing Y in, "
sale of Lattice shares on or about November 3, 2016 in
this account; and
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e. A sum of $144, 710 .11 held at Interactive Brokers, LLC in
an account with the last four digits 3862 in the name
representing the net proceeds from the sale
"Lizhao Su, "
of Lattice shares on or about November 3, 2016 in this
account .
Substitute Asset Provision
If any of the above described forfeitable property, as
40.
a result of any act or omission of the defendant :
a.
b.
c.
d.
cannot be located upon the exercise of due
dil igence ;
has been transferred or sold to, or deposited with,
a third person;
has been placed beyond the jurisdiction of the
Court ;
has been substantially diminished in value; or
has been commingled with other property which
cannot be subdivided without difficulty ;
it is the intent of the United States, pursuant to Title 21, United
States Code, Section 853 (p) and Title 28, United States Code,
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Section 2461 (c), to seek forfeiture
of any other property of the
defendant up to the value of the above forfeitable property .
(Title 18, United States Code, Section 981,
Title 21, United States Code, Section 853 (p) , and
Title 28, United States Code, Section 2461 (c) . )
FOREPERSON
BERMAN
GEOFFR Y
United States Attorney
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STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
MICHAEL YIN,
a/ k/ a "Shaohua Yin, "
De f endant .
INDICTMENT
18 Cr.
(Title 18, United States Code, Sections
371, 1348 & 2; Title 15, United States
Code, Sections 78 j (b) & 78ff; and Title
17, Code of Federal Regulations,
Section 240. 10b-5)
GEOFFREY S. BERMAN
United States Attorney.
A TRUE BILL
Fore
rson.
21