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U.S. Securities and Exchange Commission

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION


SECURITIES AND EXCHANGE COMMISSION

Plaintiff,

v.

JOSEPH SIDORYK, GARY L. CAMP,
TODD CAMP and THOMAS J. SISKA

Defendants.


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Case No.

COMPLAINT FOR PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF

Plaintiff, Securities and Exchange Commission ("Plaintiff Commission"), alleges the following:

NATURE OF THE COMPLAINT

1. This matter involves illegal insider trading and tipping by Joseph Sidoryk ("Defendant Sidoryk") and illegal insider trading by three of his tippees, Gary L. Camp ("Defendant Gary Camp"), Todd Camp ("Defendant Todd Camp") and Thomas J. Siska ("Defendant Siska"), all in the stock of Three-Five Systems, Inc. ("Three-Five"). In late May through early July of 2000, Defendant Sidoryk, the Director of Strategic Accounts for Motorola Worldwide at Three-Five, possessed confidential information that Three-Five's largest customer, Motorola, Inc. ("Motorola"), would be significantly reducing its order for the second-half of 2000. As a result, on July 12, 2000, Three-Five issued a public announcement that materially and negatively impacted the value of its stock. Prior to the public announcement, Defendant Sidoryk communicated confidential information about the significantly reduced Motorola order to Defendants Gary Camp, Todd Camp and Siska. While in possession of this confidential information and prior to the public announcement, Defendants Sidoryk, Gary Camp and Siska each sold their entire holdings in Three-Five and Defendant Todd Camp sold short Three-Five stock. As a result, these trades resulted in approximately $29,816.19 in losses avoided and approximately $15,343.75 in realized and unrealized gains by Defendants Sidoryk, Gary Camp, Todd Camp and Siska from their illegal insider trading.

2. Defendants Sidoryk, Gary Camp, Todd Camp and Siska, directly and indirectly, have engaged and, unless enjoined, will continue to engage in acts, practices, and courses of business which constitute and will constitute violations of Section 17(a) of the Securities Act of 1933 ("Securities Act") [15 U.S.C. §77q(a)] and Section 10(b) of the Securities Exchange Act of 1934 ("Exchange Act") and Rule 10b-5 thereunder [15 U.S.C. §78j(b) and 17 C.F.R. §240.10b-5].

3. Plaintiff Commission brings this action to enjoin such acts, practices, and courses of business, and for other equitable relief pursuant to Section 20(b) of the Securities Act [15 U.S.C. §77t(b)] and Sections 21(d), 21(e) and 21A of the Exchange Act [15 U.S.C. §§78u(d), 78u(e) and 78u-1(a)].

JURISDICTION AND VENUE

4. The Court has jurisdiction over this action pursuant to Section 22(a) of the Securities Act [15 U.S.C. §77v(a)] and Sections 21 and 27 of the Exchange Act [15 U.S.C. §§78u and 78aa].

5. Defendants Sidoryk, Gary Camp, Todd Camp and Siska will, directly and indirectly, unless enjoined, have the opportunity to engage in the acts, practices, and courses of business set forth in this Complaint and in acts, practices, and courses of business of similar purport and object.

6. The acts, practices, and courses of business constituting the violations herein have occurred within the jurisdiction of the United States District Court for the Northern District of Illinois and elsewhere.

7. Defendants Sidoryk, Gary Camp, Todd Camp and Siska, directly and indirectly, have made use of the means and instrumentalities of interstate commerce and of the mails in connection with the acts, practices, and courses of business alleged herein within the jurisdiction of the Northern District of Illinois and elsewhere.

1 THE DEFENDANTS

8. Defendant Sidoryk, age 36, lives in Elmhurst, Illinois. At all relevant times, Defendant Sidoryk was employed by Three-Five as the Director of Strategic Accounts for Motorola Worldwide. At all relevant times, Defendant Sidoryk was related by marriage to both Defendants Gary Camp and Todd Camp and was a friend of Defendant Siska.

9. Defendant Gary Camp, age 62, lives in Rock Island, Illinois and is retired. Defendant Gary Camp was a chartered financial analyst and served as an investment manager of a non-profit, fraternal benefit society for twenty-nine years. At all relevant times, Defendant Gary Camp was the father-in-law of Defendant Sidoryk. Defendant Gary Camp is Defendant Todd Camp's father.

10. Defendant Todd Camp, age 39, lives approximately five blocks from Defendant Sidoryk in Elmhurst, Illinois. Defendant Todd Camp is employed as a vice-president of a publicly-held bank and recently resigned his designation as a chartered financial analyst. At all relevant times, Defendant Todd Camp was the brother-in-law of Defendant Sidoryk. Defendant Todd Camp is Defendant Gary Camp's son.

11. Defendant Siska, age 67, lives in Norridge, Illinois and is self-employed. At all relevant times, Defendant Siska was a friend of Defendant Sidoryk.

2 ENTITIES INVOLVED

12. At all relevant times, Three-Five was a Delaware corporation with its principal offices located in Tempe, Arizona. Three-Five is a publicly-held company, whose common stock is registered pursuant to Section 12(b) of the Exchange Act [15 U.S.C. §78(b)]. Three-Five's stock is listed on the New York Stock Exchange ("NYSE"). Among other things, Three-Five specializes in the design and manufacture of liquid crystal display ("LCD") products used for operational control and display in wireless communication devices.

13. At all relevant times, Motorola was a Delaware corporation with its principal offices located in Schaumburg, Illinois and was a major customer of Three-Five. Motorola is a publicly-held company, whose common stock is registered pursuant to Section 12(b) of the Exchange Act [15 U.S.C. §78(b)]. Motorola's stock is listed on the NYSE. Among other things, Motorola designs, manufactures and sells wireless communication products.

FACTS

Defendant Sidoryk Was Aware of the Significantly Reduced Motorola Order to Three-Five for the Second-Half of 2000.

14. In or about September 1998, Defendant Sidoryk was hired as the Director of Strategic Accounts, Motorola Worldwide at Three-Five. At all relevant times, Defendant Sidoryk was Three-Five's primary sales contact with Motorola and his duties and responsibilities were exclusively devoted to securing sales to Motorola.

15. Defendant Sidoryk, in the course of his employment with Three-Five, had possession of and access to confidential information related to Three-Five sales to Motorola.

16. Defendant Sidoryk was aware that Three-Five originally anticipated that Motorola would order approximately 23 million LCD units for the year 2000.

17. In or about early 2000, Motorola initially reduced its order for the year 2000 to approximately 19 million LCD units, and later to approximately 11 million LCD units, or by approximately 52%. Motorola communicated these reductions to Three-Five, including Defendant Sidoryk, through informal, non-public discussions.

18. During the first half of 2000, Motorola made up approximately 85% to 90% of Three-Five's business.

19. On or about May 24, 2000, Defendant Sidoryk attended a business review meeting between Three-Five and Motorola. During the meeting, Motorola confirmed its prior, informal non-public discussions with Three-Five that it would be reducing its order for the year 2000 to approximately 11 million LCD units, or by approximately 52%.

20. Three-Five's Chief Financial Officer ("CFO") arranged, through Defendant Sidoryk, a meeting between senior level Motorola and Three-Five executives about Motorola's reduced order. On or about June 26, 2000, Defendant Sidoryk received confirmation that the meeting would take place on or about July 7, 2000.

21. On or about July 7, 2000, Defendant Sidoryk, Three-Five's CFO and Chief Executive Officer attended the meeting with Motorola.

22. Three-Five originally anticipated that Motorola would order approximately 16 million LCD units for the second-half of 2000.

23. At the July 7, 2000 meeting, Motorola indicated that it would order approximately 6.2 million LCD units from Three-Five, or approximately 62% less than its original order of approximately 16 million LCD units for the second-half of 2000. The meeting lasted approximately one-and-a-half hours and ended before 6:00 pm (EST).

24. On or about July 10, 2000, Motorola notified Three-Five, including Defendant Sidoryk, that it would further reduce its order for the second-half of 2000 to approximately 5.3 million LCD units, or approximately 67 % lower than its original order of approximately 16 million LCD units for the second-half of 2000.

The July 12, 2000 Three-Five Earnings Announcement

25. On or about July 12, 2000, Three-Five released an earnings announcement after the market closed. That day, Three-Five closed at or about $62.50. Three-Five's earnings announcement indicated that it had reduced expectations of sales to Motorola for the second-half of 2000.

26. After the July 12, 2000 Three-Five earnings announcement, analysts downgraded both future earnings and ratings on Three-Five.

27. On or about July 13, 2000, Three-Five opened at approximately 11:32 am (EST) at or about $32.0625, down approximately 30 7/16 points or approximately 51% after closing at or about $62.50 the previous day. On July 13, 2000, Three-Five closed at or about $34.25 with over seven million shares of Three-Five trading that day. Three-Five's trading volume on July 13, 2000 was approximately 11 times more than its previous three-month daily average and Three-Five lost more than $600 million in market value.

Defendant Sidoryk Sold All of His Three-Five Stock After Learning About the Significantly Reduced Motorola Order to Three-Five for the Second-Half of 2000.

28. Defendant Sidoryk was aware that the information regarding the significantly reduced Motorola order to Three-Five for the second-half of 2000 was confidential information.

29. On or about June 28, 2000, Defendant Sidoryk entered a market order to sell approximately all 349 shares of his Three-Five holdings, while in possession of confidential information that Motorola was significantly reducing its order to Three-Five for the second-half of 2000.

30. On or about June 29, 2000, Defendant Sidoryk's June 28, 2000 market order was filled at or about $64.9375 per share. Defendant Sidoryk received approximately $22,663.19 in gross proceeds from the sale of his approximate 349 shares of Three-Five. When selling these shares, Defendant Sidoryk did not disclose to the purchasers of the Three-Five stock or to the public any information about the significantly reduced Motorola order to Three-Five for the second-half of 2000.

Defendant Sidoryk Was Aware of Three-Five's Insider Trading Policy.

31. At all relevant times, Three-Five had an insider trading policy that expressly prohibited employees from trading in Three-Five stock while in possession of material, non-public information. The policy also expressly prohibited employees from communicating material, non-public information "to others who may trade in securities based on the basis of that information."

32. Defendant Sidoryk was aware of Three-Five's prohibition of insider trading during the entire course of his employment at Three-Five. A copy of Three-Five's insider trading policy was contained in the offer papers Defendant Sidoryk received in or about 1998. As a Three-Five employee, Defendant Sidoryk signed an affidavit of compliance indicating that he had read Three-Five's insider trading policy.

33. On or about April 14, 1999, Defendant Sidoryk received a Three-Five internal memorandum that addressed new and revised company policies. A revised copy of Three-Five's insider trading policy was attached to the memorandum.

34. On or about October 11, 1999, Three-Five's CFO sent an email message to all Three-Five email users regarding the prohibition against discussing confidential, corporate information with non-employees. At all relevant times, Defendant Sidoryk had a Three-Five email account.

Defendant Gary Camp Sold All of His Three-Five Stock After Defendant Sidoryk Tipped Him About the Significantly Reduced Motorola Order to Three-Five for the Second-Half of 2000.

35. Defendant Gary Camp is Defendant Sidoryk's father-in-law.

36. At all relevant times, Defendant Gary Camp was aware that Defendant Sidoryk was the main Motorola sales contact at Three-Five.

37. On or about June 29, 2000, Defendant Sidoryk tipped Defendant Gary Camp about the significantly reduced Motorola order to Three-Five for the second-half of 2000.

38. At or around this time, Defendant Gary Camp was aware that it was improper for Defendant Sidoryk to communicate confidential information regarding the significantly reduced Motorola order to Three-Five for the second-half of 2000.

39. On or about June 29, 2000, Defendant Gary Camp placed a limit order (at or about $66.25) at approximately 9:45 pm (EST) to sell approximately all 600 shares of his Three-Five holdings while in possession of confidential information that Motorola was significantly reducing its order to Three-Five for the second-half of 2000.

40. On or about June 30, 2000, Defendant Gary Camp changed the prior day's limit order to sell approximately all of his 600 shares of Three-Five to a market order while in possession of confidential information that Motorola was significantly reducing its order to Three-Five for the second-half of 2000.

41. On or about July 2, 2000, Defendant Gary Camp's June 30, 2000 market order was filled at or about $59 per share. Defendant Gary Camp received approximately $35,400 in gross proceeds from the sale of his approximate 600 shares of Three-Five. When selling these shares, Defendant Gary Camp did not disclose to the purchasers of the Three-Five stock or to the public any information about the significantly reduced Motorola order to Three-Five for the second-half of 2000.

Defendant Todd Camp Shorted Three-Five Stock After Defendant Sidoryk Tipped Him About the Significantly Reduced Motorola Order to Three-Five for the Second-Half of 2000.

42. Defendants Todd Camp and Sidoryk are brothers-in-law.

43. At all relevant times, Defendant Todd Camp was aware that Defendant Sidoryk was the main Motorola sales contact at Three-Five.

44. On or about July 7, 2000, Defendant Sidoryk tipped Defendant Todd Camp about the significantly reduced Motorola order to Three-Five for the second-half of 2000.

45. At or around this time, Defendant Todd Camp was aware that it was improper for Defendant Sidoryk to communicate confidential information regarding the significantly reduced Motorola order to Three-Five for the second-half of 2000.

46. On or about July 10, 2000, Defendant Todd Camp attempted to sell short approximately 500 shares of Three-Five while in possession of confidential information that Motorola was significantly reducing its order to Three-Five for the second-half of 2000. Defendant Todd Camp improperly entered the short sale as a long sale on his computer.

47. On or about July 11, 2000, Defendant Todd Camp was required by his broker to repurchase the approximately 500 shares of Three-Five that he improperly sold long on or about July 10, 2000.

48. On or about July 11, 2000, after the required buy-back of the approximate 500 shares of Three-Five, Defendant Todd Camp sold short approximately 500 shares of Three-Five at or about $63.875 per share while in possession of confidential information that Motorola was significantly reducing its order to Three-Five for the second-half of 2000. When short-selling these shares, Defendant Todd Camp did not disclose to the purchasers and sellers of the Three-Five stock or to the public any information about the significantly reduced Motorola order to Three-Five for the second-half of 2000.

49. On or about July 13, 2000, Defendant Todd Camp covered his short sale by purchasing approximately 500 shares of Three-Five at or about $33.1875 per share. Defendant Todd Camp received realized and unrealized gains of approximately $16,593.75 from the short sale of approximately 500 shares of Three-Five.

Defendant Siska Sold All of His Three-Five Stock After Defendant Sidoryk Tipped Him About the Significantly Reduced Motorola Order to Three-Five for the Second-Half of 2000.

50. Defendants Siska and Sidoryk are close friends and have known each other for over twenty-five years.

51. At all relevant times, Defendant Siska was aware that Defendant Sidoryk was the main Motorola sales contact at Three-Five.

52. On or about July 7, 2000 and on or about July 9, 2000, Defendant Sidoryk tipped Defendant Siska about the significantly reduced Motorola order to Three-Five for the second-half of 2000.

53. At or around this time, Defendant Siska was aware that it was improper for Defendant Sidoryk to communicate confidential information regarding the significantly reduced Motorola order to Three-Five for the second-half of 2000.

54. On or about July 10, 2000, Defendant Siska sold approximately all 150 shares of his Three-Five holdings at or about $62.625 per share, while in possession of confidential information that Motorola was significantly reducing its order to Three-Five for the second-half of 2000. Defendant Siska received approximately $9,393.75 in gross proceeds from the sale of his approximate 150 shares of Three-Five. When selling these shares, Defendant Siska did not disclose to the purchasers of the Three-Five stock or to the public any information about the significantly reduced Motorola order to Three-Five for the second-half of 2000.

Pattern of Coordinating Other Trades in Three-Five Stock

55. On or about January 10, 2000, approximately six months prior to Defendants Gary Camp, Todd Camp and Siska's illegal trades, they all purchased shares of Three-Five stock before a positive Three-Five public announcement.

56. On or about July 13 through July 26 of 2000, approximately a few days after Defendants Sidoryk, Gary Camp and Todd Camp's illegal trades, they all repurchased shares of Three-Five stock.

The Defendants' Ill-Gotten Gains

57. On or about July 12, 2000, Three-Five closed at or about $62.50. After the market closed on or about July 12, 2000, Three-Five released its earnings announcement. On or about July 13, 2000, Three-Five opened at or about $32.0625, down approximately 51% from the previous day's closing price. Three-Five closed at or about $34.25 on July 13, 2000.

58. Defendant Sidoryk's sale of approximately 349 shares of Three-Five stock, while in possession of confidential information that Motorola was significantly reducing its order to Three-Five for the second-half of 2000, resulted in a loss avoidance of approximately $10,709.94.

59. Defendant Sidoryk communicated confidential information regarding the significantly reduced Motorola order to Three-Five for the second-half of 2000 to Defendant Gary Camp. As a result of Defendant Gary Camp's sale of approximately 600 shares of Three-Five stock, while in possession of confidential information, he avoided losses of approximately $14,850.

60. Defendant Sidoryk communicated confidential information regarding the significantly reduced Motorola order to Three-Five for the second-half of 2000 to Defendant Todd Camp. As a result of Defendant Todd Camp's short-sale of approximately 500 shares of Three-Five stock, while in possession of confidential information, he received realized and unrealized gains of approximately $16,593.75.

61. Defendant Sidoryk communicated confidential information regarding the significantly reduced Motorola order to Three-Five for the second-half of 2000 to Defendant Siska. As a result of Defendant Siska's sale of approximately 150 shares of Three-Five stock, while in possession of confidential information, he avoided losses of approximately $4,256.25.

COUNT I

Violations of Section 17(a)(1) of the Securities Act [15 U.S.C. § 77q(a)(1)]

62. Paragraphs 1 through 61 are realleged and incorporated by reference.

63. At all times alleged in this Complaint, Defendants Sidoryk, Gary Camp, Todd Camp and Siska, in the offer and sale of securities, namely the securities of Three-Five, by the use of the means and instruments of transportation and communication in interstate commerce and by the use of the mails, directly and indirectly, employed devices, schemes and artifices to defraud.

64. As part of his conduct, Defendant Sidoryk, in breach of his duty to Three-Five and its shareholders, sold Three-Five securities while in possession of material, non-public information, as described in Paragraphs 62 and 63 above.

65. As part of his conduct, Defendant Sidoryk, in breach of his duty to Three-Five and its shareholders, provided material, non-public information regarding transactions related to Three-Five to Defendants Gary Camp, Todd Camp and Siska, as described in Paragraphs 62 through 64 above.

66. As part of his conduct, Defendant Gary Camp sold shares of Three-Five while in possession of material, non-public information regarding Three-Five securities and while he knew or should have known that the information was obtained as a result of a breach of duty owed to Three-Five and its shareholders by Defendant Sidoryk, as described in Paragraphs 62 through 65 above.

67. As part of his conduct, Defendant Todd Camp sold short shares of Three-Five while in possession of material, non-public information regarding Three-Five securities and while he knew or should have known that the information was obtained as a result of a breach of duty owed to Three-Five and its shareholders by Defendant Sidoryk, as described in Paragraphs 62 through 65 above.

68. As part of his conduct, Defendant Siska sold shares of Three-Five while in possession of material, non-public information regarding Three-Five securities and while he knew or should have known that the information was obtained as a result of a breach of duty owed to Three-Five and its shareholders by Defendant Sidoryk, as described in Paragraphs 62 through 65 above.

69. Defendants Sidoryk, Gary Camp, Todd Camp and Siska each knew or were reckless in not knowing the facts and circumstances described in Paragraphs 62 through 68 above.

70. As a result of the activities described in Paragraphs 62 through 69 above, Defendants Sidoryk, Gary Camp, Todd Camp and Siska each violated Section 17(a)(1) of the Securities Act [15 U.S.C. § 77q(a)(1)].

COUNT II

Violations of Sections 17(a)(2) and 17(a)(3) of the Securities Act

[15 U.S.C. §§ 77q(a)(2) and 77q(a)(3)]

71. Paragraphs 1 through 61 are realleged and incorporated by reference.

72. At all times alleged in this Complaint, Defendants Sidoryk, Gary Camp, Todd Camp and Siska, in the offer and sale of securities, namely the securities of Three-Five, by the use of the means and instruments of transportation and communication in interstate commerce and by the use of the mails, directly and indirectly, obtained property by means of untrue statements of material fact or omissions to state material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading, and engaged in transactions, practices or courses of business which operated as a fraud and deceit upon purchasers of securities.

73. As a result of the activities described in Paragraphs 71 and 72, Defendants Sidoryk, Gary Camp, Todd Camp and Siska each violated Sections 17(a)(2) and 17(a)(3) of the Securities Act [15 U.S.C. §§ 77q(a)(2) and 77q(a)(3)].

COUNT III

Violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder

[15 U.S.C. §78j(b) and 17 C.F.R. §240.10b-5]

74. Paragraphs 1 through 61 are realleged and incorporated by reference.

75. At all times alleged in this Complaint, Defendants Sidoryk, Gary Camp, Todd Camp and Siska, in connection with the purchase and sale of securities, namely the securities of Three-Five, and by the use of the means and instrumentalities of interstate commerce and by the use of the mails, directly and indirectly employed devices, schemes and artifices to defraud, made untrue statements of material fact and omitted 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 engaged in acts, practices and courses of business which operated as a fraud and deceit upon purchasers and prospective purchasers and sellers of securities.

76. As part of his conduct, Defendant Sidoryk, in breach of his duty to Three-Five and its shareholders, sold Three-Five securities while in possession of material, non-public information, as described in Paragraphs 74 and 75 above.

77. As part of his conduct, Defendant Sidoryk, in breach of his duty to Three-Five and its shareholders, provided material, non-public information regarding transactions related to Three-Five to Defendants Gary Camp, Todd Camp and Siska, as described in Paragraphs 74 through 76 above.

78. As part of his conduct, Defendant Gary Camp sold shares of Three-Five while in possession of material, non-public information regarding Three-Five securities and while he knew or should have known that the information was obtained as a result of a breach of duty owed to Three-Five and its shareholders by Defendant Sidoryk, as described in Paragraphs 74 through 77 above.

79. As part of his conduct, Defendant Todd Camp sold short shares of Three-Five while in possession of material, non-public information regarding Three-Five securities and while he knew or should have known that the information was obtained as a result of a breach of duty owed to Three-Five and its shareholders by Defendant Sidoryk, as described in Paragraphs 74 through 78 above.

80. As part of his conduct, Defendant Siska sold shares of Three-Five while in possession of material, non-public information regarding Three-Five securities and while he knew or should have known that the information was obtained as a result of a breach of duty owed to Three-Five and its shareholders by Defendant Sidoryk, as described in Paragraphs 74 through 79 above.

81. Defendants Sidoryk, Gary Camp, Todd Camp and Siska each knew or were reckless in not knowing the facts and circumstances described in Paragraphs 74 through 80 above.

82. As a result of the activities described in Paragraphs 74 and 81 above, Defendants Sidoryk, Gary Camp, Todd Camp and Siska each violated Section 10(b) of the Exchange Act and Rule 10b-5 thereunder [15 U.S.C. §78j(b) and 17 C.F.R. §240.10b-5].

RELIEF REQUESTED

THEREFORE, Plaintiff Commission respectfully requests that this Court:

I.

Find that Defendants Sidoryk, Gary Camp, Todd Camp and Siska committed the violations alleged above.

II.

Grant a Final Judgment and an Order of Permanent Injunction and Other Equitable Relief ("Final Judgment"), in a form consistent with Rule 65(d) of the Federal Rules of Civil Procedures, enjoining Defendants Sidoryk, Gary Camp, Todd Camp and Siska, their officers, agents, servants, employees, attorneys and those persons in active concert or participation with them who receive actual notice of the Final Judgment by personal service or otherwise, and each of them from, directly or indirectly, as principals or aiders and abettors, by the use of mails or any means or instrumentalities of interstate commerce, engaging in the unlawful acts, practices or courses of business described above, or any conduct of similar purport and object, in connection with the transactions in the securities described in this Complaint or any other security, including violations of Sections 17(a)(1), 17(a)(2) and 17(a)(3) of the Securities Act [15 U.S.C. §§ 77q(a)(1), 77q(a)(2) and 77q(a)(3)].

III.

Grant a Final Judgment, in a form consistent with Rule 65(d) of the Federal Rules of Civil Procedures, enjoining Defendants Sidoryk, Gary Camp, Todd Camp and Siska, their officers, agents, servants, employees, attorneys and those persons in active concert or participation with them who receive actual notice of the Final Judgment by personal service or otherwise, and each of them from, directly or indirectly, as principals or aiders and abettors, by the use of mails or any means or instrumentalities of interstate commerce, engaging in the unlawful acts, practices or courses of business described above, or any conduct of similar purport and object, in connection with the transactions in the securities described in this Complaint or any other security, including violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder [15 U.S.C. §78j(b) and 17 C.F.R. §240.10b-5].

IV.

Grant a Final Judgment requiring Defendants Sidoryk, Gary Camp, Todd Camp and Siska to each disgorge all ill-gotten gains resulting from their violations, plus prejudgment interest.

V.

Grant an Final Judgment requiring Defendants Sidoryk, Gary Camp, Todd Camp and Siska to each pay to Plaintiff Commission a civil penalty pursuant to Section 21A of the Exchange Act [15 U.S.C. §78u-1].

VI.

Retain jurisdiction of this action in accordance with the principles of equity and the Federal Rules of Civil Procedure in order to implement and carry out the terms of all orders and decrees that may be entered or to entertain any suitable application or motion for additional relief within the jurisdiction of this Court.

VII.

Grant an Order for such further relief as the Court may deem appropriate.

Respectfully Submitted,

Jennifer L. Klebes, PA Bar No. 83935
Tina K. Diamantopoulos, IL Bar No. 6224788

Attorneys for Plaintiff
U. S. Securities and Exchange Commission
175 W. Jackson Blvd., Suite 900
Chicago, Illinois 60604
(312) 353-7390

Dated: , 2002


http://www.sec.gov/litigation/complaints/comp17628.htm

Modified: 07/24/2002