REJECTEDWALL #258
Sam Ikkurty
Posted April 16, 2026
PERMANENT LINKcftcsucks.com/258
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Four Years, 209
Million Judgment
Sam Ikkurty | samikkurty.com | April 16, 2026
The numbers in CFTC v. Sam Ikkurty, Case No. 1:22-cv-02465 (N.D. Ill.), tell a story that
the agency’s press releases do not.
Sixty-nine limited partners invested
29.3 million in distributions — a
return of approximately 397%. Not one of those 69 investors filed a complaint with the
CFTC. Not one of them lost money. Thirty-two of them filed formal objections with the
court, asking the proceedings to stop. The fund was registered with the SEC. The
investors received 139 consecutive weekly newsletters — Five Bullet Friday —
documenting every significant development in the portfolio.
The CFTC obtained a judgment of $209 million.
That number requires explanation. The $209 million figure is not based on investor
losses, because there were none. It is not based on investor complaints, because there
were none. It is based on a disgorgement theory — the idea that all assets that passed
through the fund must be disgorged, regardless of whether investors profited. The
CFTC’s disgorgement calculation treats every dollar that moved through the fund as ill-
gotten gain, even though the investors who provided those dollars received nearly five
times their investment back.
The Supreme Court addressed this kind of disgorgement calculation in Liu v. SEC, 591
U.S. 71 (2020), holding that disgorgement must be limited to net profits and cannot
exceed the actual gains from the wrongdoing. The $209 million figure does not appear
to be consistent with Liu. This is one of the arguments now before the Seventh Circuit
on appeal, Case No. 24-2684.
There is also the question of the asset freeze. Since May 2022 — nearly four years —
every asset I own has been frozen. I cannot pay legal fees without court approval. I
cannot access my own bank accounts. The freeze was imposed in an eleven-minute ex
0inInvestorLosses, anda
5.9millioninRoseCityIncomeF und.T heyreceived
Million Judgment
Sam Ikkurty | samikkurty.com | April 16, 2026
The numbers in CFTC v. Sam Ikkurty, Case No. 1:22-cv-02465 (N.D. Ill.), tell a story that
the agency’s press releases do not.
Sixty-nine limited partners invested
29.3 million in distributions — a
return of approximately 397%. Not one of those 69 investors filed a complaint with the
CFTC. Not one of them lost money. Thirty-two of them filed formal objections with the
court, asking the proceedings to stop. The fund was registered with the SEC. The
investors received 139 consecutive weekly newsletters — Five Bullet Friday —
documenting every significant development in the portfolio.
The CFTC obtained a judgment of $209 million.
That number requires explanation. The $209 million figure is not based on investor
losses, because there were none. It is not based on investor complaints, because there
were none. It is based on a disgorgement theory — the idea that all assets that passed
through the fund must be disgorged, regardless of whether investors profited. The
CFTC’s disgorgement calculation treats every dollar that moved through the fund as ill-
gotten gain, even though the investors who provided those dollars received nearly five
times their investment back.
The Supreme Court addressed this kind of disgorgement calculation in Liu v. SEC, 591
U.S. 71 (2020), holding that disgorgement must be limited to net profits and cannot
exceed the actual gains from the wrongdoing. The $209 million figure does not appear
to be consistent with Liu. This is one of the arguments now before the Seventh Circuit
on appeal, Case No. 24-2684.
There is also the question of the asset freeze. Since May 2022 — nearly four years —
every asset I own has been frozen. I cannot pay legal fees without court approval. I
cannot access my own bank accounts. The freeze was imposed in an eleven-minute ex
0inInvestorLosses, anda
5.9millioninRoseCityIncomeF und.T heyreceived
parte hearing at which I was not present. The CFTC’s lead investigator admitted she
never reviewed the blockchain. The DOJ declined to bring criminal charges. And yet
the freeze continues.
The CFTC’s own expert witness testified that the fund was not a Ponzi scheme. The
agency’s theory of fraud required proving that I knew the fund was insolvent and
continued raising money anyway. The blockchain — which the lead investigator never
reviewed — shows 885 transactions that directly contradict the CFTC’s Genie
Technologies theory of how the fund operated.
Four years. Zero investor losses. A 397% return to investors. A $209 million judgment.
An investigator who never looked at the blockchain. A DOJ that declined criminal
charges. Thirty-two investors who asked the court to stop.
The Seventh Circuit is now reviewing whether any of this makes sense. The appeal is
pending. The asset freeze continues. The math still does not add up.
The Numbers
never reviewed the blockchain. The DOJ declined to bring criminal charges. And yet
the freeze continues.
The CFTC’s own expert witness testified that the fund was not a Ponzi scheme. The
agency’s theory of fraud required proving that I knew the fund was insolvent and
continued raising money anyway. The blockchain — which the lead investigator never
reviewed — shows 885 transactions that directly contradict the CFTC’s Genie
Technologies theory of how the fund operated.
Four years. Zero investor losses. A 397% return to investors. A $209 million judgment.
An investigator who never looked at the blockchain. A DOJ that declined criminal
charges. Thirty-two investors who asked the court to stop.
The Seventh Circuit is now reviewing whether any of this makes sense. The appeal is
pending. The asset freeze continues. The math still does not add up.
The Numbers
Metric Figure
Investors 69 limited partners
Total Invested $5.9 million
Total Returned $29.3 million
Return on Investment 397%
Investor Losses $0
Investor Complaints to CFTC 0
Investors Who Objected to Case 32 (formal court filings)
Weekly Newsletters Sent 139 consecutive
CFTC Judgment $209 million
Asset Freeze Duration Nearly 4 years (May 2022 ‒ present)
DOJ Criminal Charges Declined
CFTC Expert’s Ponzi Finding Not a Ponzi scheme
The Legal Question
Under
Liu v. SEC, 591 U.S. 71 (2020), disgorgement in SEC and CFTC enforcement
actions must be limited to net profits — it cannot be a penalty in excess of actual gains
from the wrongdoing. When investors received a 397% return, the “net profit” from the
alleged wrongdoing is difficult to calculate as $209 million. The Seventh Circuit, in
Appeal No. 24-2684, is being asked to apply Liu to the disgorgement calculation in this
case.
Published April 16, 2026 | samikkurty.com Case No. 1:22-cv-02465 (N.D. Ill.) | 7th Cir.
Appeal No. 24-2684 | Liu v. SEC, 591 U.S. 71 (2020)
Investors 69 limited partners
Total Invested $5.9 million
Total Returned $29.3 million
Return on Investment 397%
Investor Losses $0
Investor Complaints to CFTC 0
Investors Who Objected to Case 32 (formal court filings)
Weekly Newsletters Sent 139 consecutive
CFTC Judgment $209 million
Asset Freeze Duration Nearly 4 years (May 2022 ‒ present)
DOJ Criminal Charges Declined
CFTC Expert’s Ponzi Finding Not a Ponzi scheme
The Legal Question
Under
Liu v. SEC, 591 U.S. 71 (2020), disgorgement in SEC and CFTC enforcement
actions must be limited to net profits — it cannot be a penalty in excess of actual gains
from the wrongdoing. When investors received a 397% return, the “net profit” from the
alleged wrongdoing is difficult to calculate as $209 million. The Seventh Circuit, in
Appeal No. 24-2684, is being asked to apply Liu to the disgorgement calculation in this
case.
Published April 16, 2026 | samikkurty.com Case No. 1:22-cv-02465 (N.D. Ill.) | 7th Cir.
Appeal No. 24-2684 | Liu v. SEC, 591 U.S. 71 (2020)
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Submission trackF
StatusREJECTED
Posted2026-04-16T07:15:11.000Z
SHA-256 hash51f2ff4055eea4104ffdf44794483bc19a8aa6fb131c3d86cd81b476b8c86736
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