Understanding Regulatory and Court Orders (SEC v. SolarWinds)

Table of contents

• 1. SEC complaint
• 2. District court motion to dismiss decision
• 3. Dismissal stipulation (2025)

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Purpose

Track the SEC’s civil enforcement action against SolarWinds and its CISO (as filed), the district court’s motion to dismiss ruling, and the 2025 stipulation dismissing the case with prejudice.

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1. SEC complaint

SEC v. SolarWinds Corp. and Timothy G. Brown, No. 1:23-cv-09518 (S.D.N.Y.), filed Oct. 30, 2023.

• Complaint PDF: comp-pr2023-227.pdf
• Press release: 2023-227

The complaint alleges fraud and internal control failures relating to cybersecurity representations and the SUNBURST period. Read the complaint for specific theories.

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2. District court motion to dismiss decision

The court issued a decision on defendants’ motion to dismiss reported at 741 F. Supp. 3d 37 (July 18, 2024). Read the opinion for which claims survived or were dismissed at that stage.

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3. Dismissal stipulation (2025)

On November 20, 2025, the SEC announced a joint stipulation dismissing the enforcement action with prejudice. See Litigation Release LR-26423 and the filed stipulation.

• LR-26423: SEC litigation release

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