sec-v-milton

p. 1

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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:
UNITED STATES SECURITIES AND :
EXCHANGE COMMISSION, :
:
Plaintiff, :
: Civil Action No. 1:21-cv-6445
v. :
: JURY TRIAL DEMANDED
TREVOR R. MILTON, :
:
Defendant. :
:
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COMPLAINT
Plaintiff United States Securities and Exchange Commission (the “Commission”), for its
Complaint against Defendant Trevor R. Milton (“Milton”), alleges as follows:
SUMMARY
1. Trevor R. Milton, the founder, largest stockholder, and former Chief Executive
Officer and Executive Chairman of Nikola Corporation (“Nikola”), a publicly traded company,
engaged in a fraudulent scheme to deceive retail investors about Nikola’s products, technical
advancements, and commercial prospects for his own personal benefit in violation of the federal
securities laws. Milton did so primarily by leveraging his social media presence and frequent
appearances on television and podcasts to flood the market with false and misleading
information about Nikola.
2. Milton founded Nikola in 2015 with the primary goals of manufacturing semi-
trucks that run on alternative fuels with low or zero emissions and building an alternative fuel
station infrastructure to support those vehicles. To accomplish these goals, Nikola needed to
Case 1:21-cv-06445 Document 1 Filed 07/29/21 Page 1 of 65
Sections
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