Bluesky Eagle Capital Management Ltd.

U.S. SECURITIES AND EXCHANGE COMMISSION

Litigation Release No. 26484 / February 19, 2026

Securities and Exchange Commission v. Bluesky Eagle Capital Management Ltd., No. 1:25-cv-09507-AS (S.D.N.Y. filed Nov. 13, 2025)

SEC Obtains Final Judgment against Investment Adviser Charged with Making Misrepresentations in SEC Filing

On February 11, 2026, the U.S. District Court for the Southern District of New York entered a final judgment by default against purported investment adviser Bluesky Eagle Capital Management Ltd. in connection with previously filed charges for making material misrepresentations and unsubstantiated statements in a form filed with the SEC.

The SEC’s complaint, filed on November 13, 2025, alleged that in its December 2023 Form ADV, Bluesky Eagle represented that it is an Exempt Reporting Adviser (a category of private fund advisers that are not required to register with the SEC); that it is a public company operating from office space in New York City; that it manages $10 million in assets in the United States; that it advises a private fund; and that a separate registered investment adviser (RIA) reports information about the private fund on its own Form ADV. Contrary to Bluesky Eagle's representations, the complaint alleged that the real estate manager of the New York office space had no knowledge of Bluesky Eagle or its purported executives, and the separate RIA had not reported information about the purported private fund. The complaint also alleged that the Commission had not found any reporting of information about the private fund on other filings with the SEC, and that a search of the Commission's public company database yielded no information on Bluesky Eagle. Additionally, the SEC alleged that Bluesky Eagle failed to respond to a request by Commission attorneys to provide records to substantiate the information on its Form ADV.

The final judgment permanently enjoins Bluesky Eagle from future violations of Sections 204(a) and 207 of the Investment Advisers Act of 1940, and permanently enjoins Bluesky Eagle, its owners, and its executive officers from filing a Form ADV as an Exempt Reporting Adviser. In addition, the judgment orders Bluesky Eagle to pay a civil penalty of $1,182,254.

The SEC's litigation was conducted by Alexandra Lavin, Xinyue Angela Lin, David London, Sarah McAteer, Ryan Murphy, Michele Perillo, and Dahlia Rin of the SEC's Boston Regional Office. The SEC appreciates the assistance of the Financial Industry Regulatory Authority.