UNITED STATES OF AMERICA
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
Release No. 41949 / September 30, 1999
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
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").
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.
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
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