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."
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