Pilots Fly Stocks on Secret Biotech Fund Info!

SEC v. Joseph C. Lewis, Carolyn W. Carter, Patrick J. O’Connor, et al. — U.S. Securities and Exchange Commission Litigation Release No. 26489, dated February 24, 2026.

The SEC charged Joseph C. Lewis and associates with insider trading. Lewis allegedly shared material nonpublic information about two companies with his girlfriend, Carolyn W. Carter, and his private pilots, Patrick J. O’Connor and Bryan L. Waugh. These individuals then traded on the information, generating ill-gotten profits. Final judgments were entered against all four defendants, requiring them to pay penalties, disgorgement, and prejudgment interest.

In Plain English

Imagine someone knows a secret about a company's stock before anyone else. This person then tells their friends, who use the secret to buy or sell the stock before the news becomes public, making money unfairly. The SEC stepped in to stop this and make them pay back the illegal profits and a penalty.

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 Inside Information Joseph C. Lewis, through his majority ownership and control of a biotechnology investment fund, obtained material, nonpublic information about two public companies.
  2. Tipping Off Girlfriend Lewis allegedly violated a duty of trust and confidence by tipping this inside information to his then-girlfriend, Carolyn W. Carter.
  3. Girlfriend Trades on Information Carter then traded in the stock of both companies based on the illegally obtained information, realizing ill-gotten profits.
  4. Tipping Off Pilots Separately, Lewis also tipped information about one of the companies to his private pilots, Patrick J. O’Connor and Bryan L. Waugh.
  5. Pilots Trade on Information O’Connor and Waugh then traded in that company’s stock based on the tipped information, also realizing ill-gotten profits.

The Enforcement Action

The SEC obtained final consent judgments as to Joseph C. Lewis, Carolyn W. Carter, Patrick J. O’Connor, and Bryan L. Waugh in its civil enforcement action. The judgments permanently enjoin the defendants from violating antifraud provisions of the Securities Exchange Act of 1934 and Rule 10b-5. The defendants were ordered to pay penalties, disgorgement, and prejudgment interest. Lewis was ordered to pay a $1,636,645.11 penalty. Carter was ordered to pay $241,154.81 in disgorgement and $43,589.44 in prejudgment interest. O’Connor was ordered to pay $24,221.53 in penalties, $171,886.12 in disgorgement, and $29,257.46 in prejudgment interest. Waugh was ordered to pay $33,126.86 in penalties, $132,507.44 in disgorgement, and $22,554.64 in prejudgment interest.

Named in this action: Joseph C. Lewis, Carolyn W. Carter, Patrick J. O’Connor, Bryan L. Waugh.