As one example, the SEC alleged, Cumberland promoted ATOM through, “An email sent to counterparties on February 20, 2023 stated: ‘At the moment, one of the smaller gainers in the sector, outside of ETH and EOS, has been ATOM. ATOM is up ‘only’ 53% YTD, despite strong fundamentals and a healthy developer community; it’s a name where we expect to see a catchup rally if crypto remain buoyant.'”