TECH TITANS CAUGHT! $1 MILLION INSIDER TRADING SCHEME EXPOSED!

SEC v. Hari Prasad Sure, Lokesh Lagudu, Chotu Prabhu Tej Pulagam, et al. — U.S. Securities and Exchange Commission Litigation Release No. 26217, dated January 14, 2025.

The SEC charged seven individuals with insider trading ahead of Twilio's positive first quarter 2020 earnings announcement. The scheme involved software engineers tipping off family and friends, who then traded Twilio options and stock, generating over $1 million in illegal profits. All defendants consented to final judgments including permanent injunctions, disgorgement of profits with interest, and civil penalties.

In Plain English

Imagine some people who work at a company know that the company is going to announce good news soon, but they aren't supposed to tell anyone. These people told their family and friends anyway. Then, the family and friends bought a lot of the company's stock and options before the good news came out. When the good news was announced, the stock price went up, and they sold their shares for a big profit. This is called insider trading, and it's illegal.

Disclaimer: all facts are drawn from the SEC's own filings; the claims described are allegations unless and until a court rules or the parties settle, and some cases end in dismissal.

How the Alleged Scheme Worked

  1. Access to Confidential Information Hari Prasad Sure, Lokesh Lagudu, and Chotu Prabhu Tej Pulagam, who were software engineers at Twilio Inc., possessed material non-public information about the company's customer usage trends. This information was critical for predicting the company's upcoming financial performance.
  2. Tipping Off Others The insider defendants, in possession of this confidential information, knowingly tipped off four other individuals: Dileep Kumar Reddy Kamujula, Sai Mounika Nekkalapudi, Abhishek Dharmapurikar, and Chetan Prabhu Sree Karteek Pulagam. These individuals were family members and friends of the software engineers.
  3. Trading on Inside Information Following the tips, Kamujula, Nekkalapudi, Dharmapurikar, and Chetan Pulagam engaged in trading activities involving Twilio's stock and options. These trades were executed in advance of Twilio's positive first quarter 2020 earnings announcement, scheduled for May 6, 2020.
  4. Generating Illegal Profits The insider trading scheme was successful in generating substantial illegal profits. The SEC's complaint alleges that the scheme collectively yielded more than $1 million in illicit trading gains for the defendants.

The Enforcement Action

On January 9, 2025, the U.S. District Court for the Northern District of California entered final judgments against Hari Prasad Sure, Lokesh Lagudu, Chotu Prabhu Tej Pulagam, Dileep Kumar Reddy Kamujula, Sai Mounika Nekkalapudi, Abhishek Dharmapurikar, and Chetan Prabhu Sree Karteek Pulagam, resolving the SEC’s insider trading case filed on March 28, 2022. The complaint alleged that software engineers at Twilio Inc. tipped off family members and friends to trade in advance of a positive earnings announcement, generating over $1 million in illegal profits. The defendants consented to permanent injunctive relief, disgorgement of illegal trading profits plus prejudgment interest (from Sure, Kamujula, Nekkalapudi, Dharmapurikar, and Chetan Pulagam), and civil penalties (from Lagudu, Chotu Pulagam, Nekkalapudi, Dharmapurikar, and Chetan Pulagam). Defendants Sure and Kamujula also pled guilty to parallel criminal charges.

Named in this action: Hari Prasad Sure, Lokesh Lagudu, Chotu Prabhu Tej Pulagam, Dileep Kumar Reddy Kamujula, Sai Mounika Nekkalapudi, Abhishek Dharmapurikar.