Twilio Software Engineers Hari Sure, Lokesh Lagudu and Chotu Pulagam Charged With Insider Trading

March 29, 2022

The Securities and Exchange Commission made insider trading charges against three software engineers employed at Twilio, Inc., a San Francisco-based cloud computing communications company, and four family members and friends for allegedly generating more than $1 million in collective profits by insider trading ahead of the company’s positive first quarter 2020 earnings announcement on May 6, 2020.

According to the SEC’s complaint, friends Hari Sure, Lokesh Lagudu and Chotu Pulagam were software engineers at Twilio and had access to various databases relevant to the company’s reporting of revenue. As alleged, around March 2020, they learned through the databases that Twilio’s customers had increased their usage of the company’s products and services in response to health measures taken in light of the Covid-19 pandemic, and concluded in a joint chat that Twilio’s stock price would “rise for sure.”

The SEC’s complaint alleges that despite receiving a company policy that prohibited them from insider trading, Sure, Lagudu and Chotu Pulagam knowingly tipped off, or used the brokerage accounts of, their family and close friends – Dileep Kamujula, Sai Nekkalapudi, Abhishek Dharmapurikar and Chetan Pulagam – to trade Twilio options and stock in advance of its May 6, 2020 earnings announcement while in possession of the confidential information concerning customer usage. According to the complaint, the scheme generated more than $1 million in illegal trading profits.

"We allege that this insider trading ring took advantage of valuable revenue information related to the pandemic at a San Francisco tech company," said Monique C. Winkler, Acting Regional Director of the SEC’s San Francisco Regional Office. "We are holding these alleged tippers and tippees accountable for their roles in the scheme."

The SEC’s complaint, filed in the Northern District of California, charges each of the defendants with violating the antifraud provisions of Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder.

Today, the U.S. Attorney’s Office for the Northern District of California announced criminal charges against Dileep Kamujula.

The SEC’s investigation, which is continuing, was conducted by Erin Wilk and Elena Ro of the San Francisco Regional Office, with assistance from Jan Jindra of the SEC’s Division of Economic and Risk Analysis, as well as John Rymas of the Market Abuse Unit’s Analysis and Detection Center. The case was supervised by Jennifer J. Lee of the San Francisco Regional Office. The litigation will be led by Susan LaMarca, Ms. Wilk and Ms. Ro.

The SEC appreciates the assistance of the U.S. Attorney’s Office for the Northern District of California, the FBI, and the Financial Industry Regulatory Authority (FINRA).