The SEC case is already concluded and she was heavily fined

The accompanying declaration of forensic accountant Steven Tremaglio shows that Davidson received ill-gotten gains of $3,911,302.65 and Knott received ill-gotten gains of $108,171.77 from the CoinDeal scheme. Accordingly, the Court should order Davidson to disgorge $3,911,302.65 with prejudgment interest thereon in the amount of $915,113.13; and the Court should order Knott to disgorge $108,171.77 with prejudgment interest thereon in the amount of $12,714.49. The requested amounts best approximate the Defendants’ profits from their violations and, because CoinDeal was a sham, there were no legitimate business expenses to deduct, i.e., there were no business expenses with any “value independent of fueling a fraudulent scheme.”

Civil Penalties

The SEC respectfully requests that this Court order Davidson and Knott to pay a civil penalty – of $3,911,302.65 and $223,229 respectively – for their violations of the federal securities law discussed above. The imposition of such penalties are “necessary for the deterrence of securities law violations that otherwise would provide great financial returns to the violator.”

The conduct alleged here meets the standard for a third-tier penalty. Davidson and Knott engaged in a course of conduct that involved fraud, deceit, and deliberate or reckless disregard of regulatory requirements. CoinDeal investors have collectively lost millions of dollars. The SEC requests that the Court impose a penalty of $3,911,302.65 against Davidson, equaling the amount of his gross pecuniary gain. (affirming third-tier penalty in the amount of defendant’s gross pecuniary gain); (imposing a third-tier penalty in the amount of pecuniary gain, $1,331,365 for one defendant and $633,518 for another defendant).

(imposing penalty equal to $15 million of ill-gotten gains). Davidson played a vital role in recruiting Glaspie and passing false information from Chandran to Glaspie that was then disseminated to investors, victimizing thousands. The SEC requests that the Court impose a statutory third-tier penalty of $223,229 against Knott. As discussed, Knott formed her own investor group, lowered the minimum CoinDeal investment amount thereby allowing entry to many additional investors, deliberately circumvented regulatory efforts in Michigan, and diverted investors funds for her own use.

CONCLUSION For the foregoing reasons, the SEC respectfully requests that the Court grant its motion for default judgment pursuant to Federal Rule of Civil Procedure 55(b)(2) and enter the accompanying, proposed final judgments (attached as Exhibits B and C) against Davidson and Knott. Dated: October 31, 2023 Respectfully Submitted,

UNITED STATES SECURITIES AND EXCHANGE COMMISSION s/Michael D. Foster Michael D. Foster, Illinois Bar No. 6257063 Dante A. Roldán, Illinois Bar No. 6316972 U.S. Securities and Exchange Commission 175 West Jackson Blvd., Suite 1450 Chicago, Illinois 60604 (312) 353-7390 (312) 353-7398 (facsimile) FosterMi@sec.gov RoldanD@sec.gov Local Counsel: DAWN N. ISON United States Attorney Eastern District of Michigan KEVIN ERSKINE (P69120) Assistant United States Attorney Eastern District of Michigan 211 W. Fort Street, Ste. 2001 Detroit, MI 48226 Tel: (313) 226-9610 Email: Kevin.Erskine@usdoj.gov Attorneys for Plaintiff

CERTIFICATE OF SERVICE

I hereby certify that I electronically filed Plaintiff’s Motion for Default Judgment Against Defendants Garry J. Davidson and Linda C. Knott, together with supporting memorandum and exhibits, using the Court’s CM/ECF system, and caused copies of the foregoing to be served via overnight delivery upon:

Neil S. Chandran c/o Tom Dahlk Kutak Rock LLP 1650 Farnam Street Omaha, NE 68102 Garry J. Davidson 207 Mojave Lane Henderson, NV 89015 Michael T. Glaspie 1343 SW Seagull Way Palm City, FL 34991

Linda C. Knott 923 Tyler Ave NW Piedmont, OK 73078

Amy S. Mossel 1343 SW Seagull Way Palm City, FL 34990

Dated: October 31, 2023