ZPR Investment Management Inc. v. Securities and Exchange Commission
Court of Appeals for the Eleventh Circuit
1Opinion of the Court
MARTIN, Circuit Judge:
Max Zavanelli and his investment firm, ZPR Investment Management, Inc. (“ZPRIM”), are before us seeking review of a final order of the Securities and Exchange Commission (“SEC” or the “Commission”). 1 The Commission found that Mr. Zavanelli and ZPRIM (the “petitioners”) made material misrepresentations to prospective clients in violation of the Investment Advisers Act of 1940 (the “Advisers Act”), 15 U.S.C. § 80b-l. Based on these violations, the Commission imposed monetary and other sanctions. After careful consideration, and with the benefit of oral argument, we grant…
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