hile they were members of the boards of directors of those companies, without disclosing their ownership and their trading of those securities. The Wylys' scheme defrauded the investing public by materially misrepresenting the Wylys' ownership and trading of the EFTA00316104 securities at issue whi

ftware's common stock was registered with the Commission pursuant to Exchange Act Section 12(b), and was traded on the New York Stock Exchange. The Wylys founded Sterling Software in 1981 and built it into one of the country's largest business software and services companies. 21. Sterling Commerce w