Court of Appeals for the Ninth Circuit October 22, 2004, No. 03-71545 (Seavey v. Securities & Exchange Commission)

MEMORANDUM *

We affirm the Security and Exchange Commission’s decision that Seavey violated §§ 206(1) and (2) of the Investment Advisers Act of 1940, 15 U.S.C. § 80b-6. Substantial evidence supports the SEC’s *912finding that Seavey’s letter to Paradigm’s investors was misleading.