On June 28th, the D.C. Circuit ordered the district court to dismiss an SEC enforcement action, without prejudice, for lack of venue. In doing so, it reversed a jury's verdict finding that defendant aided and abetted his employer's securities fraud. It rejected the SEC's co-conspirator theory of venue since defendant's alleged securities violation did not occur within the District of Columbia. The only act that occurred within the District was the filing of a Form 10-Q by defendant's employer, and that act was not attributed to defendant. SEC v. Johnson.