SECURITIES EXCHANGE ACT OF 1934
Release No. 41949 / September 30, 1999

ADMINISTRATIVE PROCEEDING
File No. 3-10054 


______________________________
                              : ORDER INSTITUTING
     In the Matter of         : ADMINISTRATIVE PROCEEDINGS
                              : PURSUANT TO SECTIONS 15(b) AND
      JENO K. KOCH,           : 19(h) OF THE SECURITIES
                              : EXCHANGE ACT OF 1934, MAKING
       Respondent.            : FINDINGS AND IMPOSING
______________________________: REMEDIAL SANCTIONS

I.

The Securities and Exchange Commission ("Commission") deems it appropriate in the public interest and for the protection of investors that public administrative proceedings be instituted pursuant to Sections 15(b) and 19(h) of the Securities Exchange Act of 1934 ("Exchange Act") against Respondent Jeno K. Koch ("Koch" or "Respondent").

II.

In anticipation of the institution of these proceedings, Koch has submitted an Offer of Settlement ("Offer") for the purpose of resolving these proceedings, which Offer the Commission has determined to accept. Solely for the purpose of these proceedings and any other proceedings brought by or on behalf of the Commission or to which the Commission is a party, Respondent, by his Offer, consents to the entry of this Order Instituting Proceedings Pursuant to Sections 15(b) and 19(h) of the Securities Exchange Act of 1934, Making Findings and Imposing Remedial Sanctions ("Order"), admits the jurisdiction of the Commission and, without admitting or denying the findings set forth herein, except with respect to paragraphs III.A. and III.D., below, which are admitted, consents to the entry of the findings and remedial sanctions set forth below.

Accordingly, it is ordered that proceedings pursuant to Sections 15(b) and 19(h) of the Exchange Act be, and hereby are, instituted.

III.

On the basis of this Order and Respondent's Offer, the Commission finds that:

A. At various times in 1995 and 1996, Koch was a registered representative of at least two broker-dealers.

B. From at least 1995 to 1996, Koch induced or effected transactions in the sales of securities by offering to sell and selling preferred stock and unregistered promissory notes issued by LSI Holdings Inc. f/k/a Legend Sports, Inc. and Legend Sports, Inc. f/k/a Sirrine & Associates, Inc. (hereinafter collectively referred to as "Legend Sports").

C. From at least 1995 to 1996, Koch induced or effected transactions in the sales of securities by recruiting others to sell and who sold preferred stock and unregistered promissory notes issued by Legend Sports.

D. On April 26, 1999, a final judgment of permanent injunction was entered, by consent, against Koch, permanently enjoining him, directly and indirectly, from violations of Sections 5(a) and 5(c) of the Securities Act of 1933, and Section 15(a) of the the Exchange Act. SEC v James T. Staples et al., Case No. 98-1061-CV- 22-C (M.D. Fla. Sept. 23, 1998).

E. The Commission's complaint alleged, in part, that Koch in connection with the offer and sale of the Legend Sports preferred stock and promissory notes, violated the registration and broker-dealer registration provisions of the federal securities laws.

F. At all relevant times, the Legend Sports preferred stock offered for sale and sold by Koch was a penny stock as defined in the Exchange Act and Rules promulgated thereunder.

IV.

In view of the foregoing, the Commission deems it appropriate in the public interest and for the protection of investors to impose the sanctions specified in Respondent's Offer.

ACCORDINGLY, IT IS ORDERED that:

A. Koch be, and hereby is, suspended from association with any broker or dealer for a period of twelve (12) months, effective on the second Monday following the entry of this Order.

B. Koch shall provide the Commission, within thirty (30) days after the end of the twelve (12) month suspension period described above, an affidavit that he has complied fully with sanction described in Section IV. A. above.

By the Commission.

Jonathan G. Katz
Secretary