16, the Commission respectfully requests that this United States District Court for the Southern District of New York: permanently enjoin Defendant John Afriyie from violating Section 10(b) of the Exchange Act 15 U.S.C. section 78j(b) and Rule 10b-5 thereunder 17 C.F.R. section 240.10b-5 ; order Defendant J

Page 6 SANCTN based on nonpublic information he learned at work.The SEC alleges that John Afriyie found out about an impending acquisition of home security company The ADT Corporation when prospective acquirer Apollo Global Management approached