Meyers Associates is an investment firm providing both advisory and investment banking services.

One of Meyers investment banking clients, IWEB (which manufactures and markets data storage

products and cloud-based software), wants to raise its stock price to facilitate a private offering,

for which it will be using Meyers as its placement agent. George works for Meyers Associates as an

investment adviser. To assist IWEB with its plans, George solicits several of his advisory clients to buy

IWEB stock, and at the same time solicits other clients to sell IWEB stock, frequently effecting matched

orders among his customers. For a 10-day period, these trades represented 48% of the total market

volume of IWEB, and the price of the stock increased from $0.12 to $0.19 and then stabilized at $0.18 for

the next several days. George’s actions are