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In the past few years, we brought two other cases involving option issues in the context of allegations relating to broader financial frauds one in 2003 involving Peregrine and one in 2004 involving Symbol Technologies.
In this regard, we identified stock options grants as a potential trouble spot several years ago well ahead of the curve.
We examined the academic literature that quantified the potential issues.
At the same time, in a related criminal action brought by the US Attorney, Kreinberg pled guilty to securities fraud and conspiracy to commit securities fraud, mail fraud and wire fraud, and he now faces up to 15 years in jail, mandatory restitution and a possible criminal fine.
Despite all the recent media attention, Brocade and Comverse are not the SEC's first stock options cases.
From my perspective, the collective efforts by the SEC are a model way of addressing an issue proceeding from various perspectives to come up with practical and wide-ranging solutions. I'd like to address this on two fronts first, I'll discuss how we got to our efforts at the Commission and then I'd like to step even further back and talk about some of my impressions on how we ended up with the option issues we are confronting.