SEC Enforcement Against Rakesh Ahuja Requires Justification for Injunctive Relief Under eBay Factors

The Southern District of New York has ordered the SEC and defendant Rakesh Ahuja to justify why a proposed final judgment satisfies the public interest factors established in SEC v. Citigroup Global Markets, Inc., including whether their request for injunctive relief is in the public interest consistent with the eBay factors.

Judge John P. Cronan issued the order on April 23, 2026, after reviewing the parties’ proposed final judgment and the Government’s letter seeking approval.

The Court directed the parties to advise by May 7, 2026, why the proposed final judgment satisfies the factors set out in SEC v. Citigroup Global Markets, Inc., 752 F.3d 285, 294-95 (2d Cir. 2014).

The order specifically requires the parties to address whether their request for injunctive relief is in the public interest consistent with the eBay factors, citing eBay Inc. v. MercExchange, L.L.C., 547 U.S. 388, 391 (2006).

The parties may state their positions in separate letters or in a joint letter.