TRAVISJ.ILES
SECURITIESCOMMISSIONER
CLINTONEDGAR
DEPUTYSECURITIESCOMMISSIONER
Mail:P.O.BOX13167
AUSTIN,TEXAS78711‐3167
Phone:(512)305‐8300
Facsimile:(512)305‐8310
Texas State Securities Board
208 E. 10th Street, 5th Floor
Austin, Texas 78701-2407
www.ssb.texas.gov
E.WALLYKINNEY
CHAIR
KENNYKONCABA
MEMBER
ROBERTBELT
MEMBER
MELISSATYROCH
MEMBER
EJIKEEOKPAII
MEMBER
SOAH DOCKET NO. 312-22-0160
TEXAS STATE SECURITIES BOARD, §
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BEFORE THE STATE OFFICE
Petitione
r
OF
v.
CELSIUS NETWORK, INC., CELSIUS
NETWORK LIMITED, CELSIUS US
HOLDING, LLC, CELSIUS NETWORK,
LLC, AND CELSIUS LENDING, LLC
Respondents
A
DMINISTRATIVE HEARINGS
CELSIUS NETWORK INC.
Service by (1) certified mail, return receipt requested, addressed to 221 River Street, 9th
Floor, Hoboken, New Jersey 07030; (2) certified mail, return receipt requested, addressed
to The Harley Building, 77-79 New Cavendish Street, London W1W 6XB, United
Kingdom; (3) certified mail, return receipt requested, addressed to its counsel John
Sikora, Jr., Partner, Latham & Watkins LLP, 330 North Wabash Avenue, Suite 2800,
Chicago, Illinois 60611; and (4) electronic mail to its counsel, John Sikora, Jr., at
CELSIUS NETWORK LIMITED
Service by (1) certified mail, return receipt requested, addressed to 221 River Street, 9th
Floor, Hoboken, New Jersey 07030; (2) certified mail, return receipt requested, addressed
to The Harley Building, 77-79 New Cavendish Street, London W1W 6XB, United
Kingdom; (3) certified mail, return receipt requested, addressed to its counsel John
Sikora, Jr., Partner, Latham & Watkins LLP, 330 North Wabash Avenue, Suite 2800,
Chicago, Illinois 60611; and (4) electronic mail to its counsel, John Sikora, Jr., at
CELSIUS US HOLDING, LLC
Service by (1) certified mail, return receipt requested, addressed to 221 River Street, 9th
Floor, Hoboken, New Jersey 07030; (2) certified mail, return receipt requested, addressed
to The Harley Building, 77-79 New Cavendish Street, London W1W 6XB, United
Kingdom; (3) certified mail, return receipt requested, addressed to its counsel John
Notice of Hearing/Celsius Network, Inc., et al./Page 2
Sikora, Jr., Partner, Latham & Watkins LLP, 330 North Wabash Avenue, Suite 2800,
Chicago, Illinois 60611; and (4) electronic mail to its counsel, John Sikora, Jr., at
CELSIUS NETWORK, LLC
Service by (1) certified mail, return receipt requested, addressed to 221 River Street, 9th
Floor, Hoboken, New Jersey 07030; (2) certified mail, return receipt requested, addressed
to The Harley Building, 77-79 New Cavendish Street, London W1W 6XB, United
Kingdom; (3) certified mail, return receipt requested, addressed to its counsel John
Sikora, Jr., Partner, Latham & Watkins LLP, 330 North Wabash Avenue, Suite 2800,
Chicago, Illinois 60611; and (4) electronic mail to its counsel, John Sikora, Jr., at
CELSIUS LENDING, LLC
Service by (1) certified mail, return receipt requested, addressed to 221 River Street,
9th Floor, Hoboken, New Jersey 07030; (2) certified mail, return receipt requested,
addressed to The Harley Building, 77-79 New Cavendish Street, London W1W 6XB,
United Kingdom; (3) certified mail, return receipt requested, addressed to its counsel
John Sikora, Jr., Partner, Latham & Watkins LLP, 330 North Wabash Avenue, Suite
2800, Chicago, Illinois 60611; and (4) electronic mail to its counsel, John Sikora, Jr., at
NOTICE OF HEARING
This is your OFFICIAL NOTICE that a hearing will commence at 9:00 AM on
FEBRUARY 14, 2022, before an Administrative Law Judge. The hearing is being held via
videoconference for the purpose of determining whether to issue a proposal for decision
for the entry of a CEASE AND DESIST ORDER against Celsius Network, Inc., Celsius
Network Limited, Celsius US Holding, LLC, Celsius Network, LLC, and Celsius Lending,
LLC (herein collectively referred to as the “Celsius Network” or as “Respondents”).
This hearing will be held pursuant to the Securities Act, Tex. Rev. Civ. Stats. Ann.
arts. 581-1-581-45 (the “Securities Act”), the Rules and Regulations of the State
Securities Board, 7 Tex. Admin. Code §§101.1-139.27 (2019) (Tex. State Sec. Bd.) (the
“Board Rules”), the Administrative Procedure Act, Tex. Gov’t Code Ann. §§2001.001-
2001.902 (the “Administrative Procedure Act”), and the Rules of Practice and Procedure
of the State Office of Administrative Hearings, 1 Tex. Admin. Code Chapter 155 (2019)
(State Ofc. of Admin. Hearings) (the “SOAH Rules”).
CELSIUS AND THE CRYPTO INTEREST ACCOUNTS
1. Celsius Network, Inc. is incorporated in Delaware and owns several subsidiaries
including an approximately 82.81% interest in Celsius Network Limited.
2. Celsius Network Limited is incorporated in England and Wales and wholly owns
many subsidiaries, including Celsius US Holding, LLC.
Notice of Hearing/Celsius Network, Inc., et al./Page 3
3. Celsius US Holding, LLC is the holding company for Celsius Network’s subsidiaries
in the United States and two of its wholly owned subsidiaries are Celsius Network,
LLC and Celsius Lending, LLC.
4. Celsius Network, LLC is a Celsius Network company incorporated in Delaware and
is the subsidiary providing Celsius Network’s user-facing services and activities for
customers in the United States.
5. Celsius Lending, LLC is a Celsius Network company incorporated in Delaware and
is the subsidiary providing consumer fiat and stablecoin loans secured by
cryptocurrency deposits to Celsius Network’s customers in the United States.
6. The Celsius Network is a network of affiliated financial services companies that
generate revenue through cryptocurrency trading, lending, and borrowing, as well
as engaging in propriety trading, mining, and other types of transactions.
7. Respondents are, in part, illegally funding their lending operations, proprietary
trading, and other revenue generating activities through the sale of unregistered
securities in the form of cryptocurrency interest-earning accounts.
8. Respondents refer to the unregistered cryptocurrency interest-earning accounts
as Celsius Network’s “Earn Rewards” program (“Celsius Earn Interest-Bearing
Account”).
9. Respondents permit Texans and other investors at least eighteen years old to
apply to purchase the Celsius Earn Interest-Bearing Account through the Celsius
Network’s website or smartphone application.
10. Investors open accounts by transferring eligible cryptocurrency to the Celsius
Network to invest in Celsius Earn Interest-Bearing Accounts. Investors relinquish
control over their cryptocurrency and the Celsius Network takes full legal and
beneficial ownership of the investors’ cryptocurrency.
11. The Celsius Network is free to use investors’ cryptocurrencies consistent with the
terms of the Celsius Earn Interest-Bearing Accounts, including commingling
cryptocurrencies with cryptocurrencies deposited by other investors, investing in
traditional financial assets and cryptocurrency assets, lending those
cryptocurrencies to institutional and corporate borrowers, and engaging in any
other activities at the Celsius Network’s discretion.
12. In exchange for consideration received in the present, the Celsius Network is
promising to pay lucrative interest rates in the future. The Celsius Network is
currently promoting the interest rates through its website, which recently advertised
an annual return of up to 17.78 percent on certain cryptocurrencies for retail
Notice of Hearing/Celsius Network, Inc., et al./Page 4
investors - well in excess of the rates currently being offered for short-term,
investment grade, fixed income securities or for bank savings accounts.
13. The Celsius Network sets the interest rates it pays on various cryptocurrencies in
advance and on a periodic basis. The Celsius Network sets its interest rates based
on various considerations and prioritizing the Celsius Network’s need for particular
types of cryptocurrencies.
14. The Celsius Network incentivizes smaller investors to invest in the Celsius Earn
Interest-Bearing Accounts by paying higher rates of interest on smaller
investments of principal for certain cryptocurrencies. As an example, the Celsius
Network has paid higher rates of interest on investments up to 1 Bitcoin and up to
100 Ethereum and lower rates of interest on investments of more than 1 Bitcoin
and more than 100 Ethereum.
15. The accrual of interest begins “as soon as any funds are credited to [an investor’s]
Celsius account.” Investors transfer cryptocurrencies to the Celsius Network and
the transaction is timestamped with the hour, minute, and second. Interest is
payable on or around the first business day of each week.
16. In the United States, interest payments are denominated in the same type of
cryptocurrency originally invested. In other jurisdictions, subject to certain
conditions, the Celsius Network may make interest payments denominated in its
native digital token, CEL.
17. Retail investors may withdraw their cryptocurrencies at any time, subject to certain
processing times.
18. As of September 3, 2021, the Celsius Network claims it has more than
$24,000,000,000 in assets under management, more than 1,000,000 community
members, and more than $8,200,000,000 in loans processed.
19. As of August 18, 2021, the Celsius Network had 348,158 active users worldwide
invested in Celsius Earn Interest-Bearing Accounts with global assets under
management exceeding $12,500,000,000. As of the same date, the Celsius
Network had 139,054 active users in the United States invested in Celsius Earn
Interest-Bearing Accounts with United States-based assets under management
exceeding $7,000,000,000.
20. As of June 9, 2021, the Celsius Network has more than $344,000,000 in assets
under management from more than 9,000 Texas residents and businesses.
CELSIUS’ API PARTNER PROGRAM
21. The Celsius Network offers an Application Programming Interface (“API”) that
allows certain institutional users, known as Celsius “API Partners,” (“Celsius API
Notice of Hearing/Celsius Network, Inc., et al./Page 5
Partners”) to integrate with the Celsius Network’s platform. Celsius API Partners
can then offer and sell the unregistered Celsius Earn Interest-Bearing Accounts to
their clients.
22. The Celsius Network provides two different types of accounts whereby Celsius API
Partners’ clients can access Celsius Earn Interest-Bearing Accounts called
segmented accounts (“Segmented API Accounts”) and omnibus accounts
(“Omnibus API Accounts”).
23. Investors who invest in Celsius Earn Interest-Bearing Accounts through a Celsius
API Partner’s Segmented API Account or Omnibus API Account are subject to the
same rights, benefits, terms, and conditions as investors who invest in Celsius
Earn Interest-Bearing Accounts directly from the Celsius Network.
24. Segmented API Accounts allow Celsius API Partners to offer Celsius Earn Interest-
Bearing Accounts through their own platforms. For Segmented API Accounts:
A. Investors create their own Celsius Network accounts through the Celsius
API Partner’s platform;
B. The Celsius Network performs the onboarding and customer due diligence
for investors from Celsius API Partners;
C. Investors must accept the Celsius Network’s terms and conditions; and
D. The Celsius API Partners receive a fee based on the percentage of interest
payable by the Celsius Network to the investor.
25. Omnibus API Accounts allow Celsius API Partners to offer and sell Celsius Earn
Interest-Bearing Accounts to their investors on an aggregated basis. For Omnibus
API Accounts:
A. The Celsius API Partner maintains one account with the Celsius Network
where it transfers the aggregated funds of its investors;
B. The Celsius Network performs no customer due diligence on the Celsius
API Partner’s investors, has no relationship with the investors, and does not
know their identities;
C. The Celsius Network’s only contractual relationship is with the Celsius API
Partner; and
D. The Celsius Network pays a fee to the Celsius API Partner which is in
addition to the interested paid on investments in the Celsius Earn Interest-
Bearing Accounts.
Notice of Hearing/Celsius Network, Inc., et al./Page 6
THE LACK OF REGISTRATION AND PUBLIC PROTECTIONS
26. Respondents are not licensed as a Money Service Business in Texas to conduct
currency exchange or money transmission activities defined by Chapter 151 of the
Texas Finance Code.
27. Respondents are not licensed with the United States Securities and Exchange
Commission. Additionally, they are not registered with the Texas State Securities
Board to offer or sell securities in Texas, as required by Section 12 of the Securities
Act, and the Celsius Earn Interest-Bearing Accounts are not registered or
permitted for sale in Texas, as required by Section 7 of the Securities Act.
Accordingly, Respondents are violating laws designed to protect Texans.
28. The Celsius Earn Interest-Bearing Accounts are also not protected by Securities
Investor Protection Corporation, otherwise known as the SIPC, a federally
mandated, non-profit, member-funded United States corporation created under the
Securities Investor Protection Act of 1970 that mandates membership of most US-
registered broker-dealers.
29. The Celsius Earn Interest-Bearing Accounts are also not insured by the Federal
Deposit Insurance Corporation, otherwise known as the FDIC, an agency that
provides deposit insurance to depositors in the United States, or the National
Credit Union Administration, otherwise known as the NCUA, an agency that
regulates and insures credit unions.
THE UNDISCLOSED RISKS
30. Respondents are not disclosing material information necessary for investors to
make an informed decision, including critical material information about the risks
associated with purchasing its unregistered securities.
31. This material information includes, without limitation, the amount of money or
cryptocurrency devoted to permissive uses, the identity, nature, and
creditworthiness of borrowers, the type and nature of transactions involving digital
assets, equities, options, and futures, the risks associated with individual digital
assets, equities, options, and futures, the profits and/or losses derived from
transactions, and financial information reflecting the assets and liabilities and
cashflow.
THE VIOLATIONS OF THE SECURITIES ACT
32. The Securities Act regulates the offer and sale of securities in Texas.
33. Section 4.A of the Securities Act defines the term securities to include traditional
products such as stocks and bonds. The statute also broadly defines the term
securities to include investment contracts, notes, and evidences of indebtedness
Notice of Hearing/Celsius Network, Inc., et al./Page 7
– broad categories of products that capture the endless number of unique and
innovative investment schemes continuously introduced into the market.
34. The mere fact an investment is tied to a cryptocurrency, blockchain technology, or
some type of digital asset does not remove it from securities regulation if it
constitutes an investment contract, note, evidence of indebtedness, or other type
of security.
35. Based on the information and allegations set forth herein, the Celsius Earn
Interest-Bearing Accounts constitute investment contracts, notes, or evidences of
indebtedness regulated as securities as that term is defined by Section 4.A of the
Securities Act.
36. Based on the information and allegations set forth herein, Respondents are
violating Section 7 of the Securities Act by offering and selling securities in Texas
that are not registered or permitted for sale in Texas.
37. Based on the information and allegations set forth herein, Respondents are also
violating Section 12 of the Securities Act by offering and selling securities in Texas
without first being registered as dealers or agents.
THE NOTIFICATION AND REQUEST FOR COMPLIANCE
38. On or about May 14, 2021, the Enforcement Division of the State Securities Board
(the “Enforcement Division”) notified Respondents that Respondents may have
offered securities in Texas that may not comply with the Securities Act.
39. The Enforcement Division also explained the regulation of the securities market in
Texas, including the identification of laws that require the registration of securities,
the registration of dealers and agents, and the truthful disclosure of all known
material facts.
40. Nevertheless, Respondents have continued to offer the Celsius Earn Interest-
Bearing Accounts to Texans in violation of Sections 7 and 12 of the Securities Act.
REMEDIES
41. The Enforcement Division is praying for a proposal for decision for the entry of an
order that Respondents immediately cease and desist from violating Sections 7
and 12 of the Securities Act.
42. Although this Notice of Hearing is praying for a proposal for decision for an order
to cease and desist from violating Sections 7 and 12 of the Securities Act, nothing
set forth herein shall preclude the Enforcement Division, consistent with applicable
law and rule, from pursuing other enforcement remedies, such as filing an
amended Notice of Hearing praying for a proposal for decision that orders the
Notice of Hearing/Celsius Network, Inc., et al./Page 8
assessment of an administrative fine or the payment of a refund/restitution to
Texans.
EXISTING CLIENT ACCOUNTS
43. This Notice of Hearing, and the prayers contained herein, do not preclude
Respondents from paying interest or returns to existing clients, refunding principal
to investors consistent with the terms of the Celsius Earn Interest-Bearing
Accounts, or otherwise lawfully dealing with existing clientele.
THE HEARING
44. The hearing will be held before the State Office of Administrative Hearings. It will
commence at 9:00 AM on FEBRUARY 14, 2022.
45. The State Office of Administrative Hearings may conduct the hearing via Zoom.
Zoom is a video conferencing platform for meetings held through the internet. The
State Office of Administrative Hearings will provide instructions for accessing the
hearing via Zoom.
46. At the hearing, the Enforcement Division will present testimony and other
admissible evidence in support of its prayer for a proposal for decision for the entry
of a CEASE AND DESIST ORDER against Respondents. Respondents will be
afforded the right to present such testimony and other evidence related thereto.
LEGAL NOTIFICATIONS
47. Legal authority and jurisdiction for this matter exist under Section 23 of the
Securities Act, Section 2003.021(b) of the Texas Government Code and Rule
155.51 of the SOAH Rules.
48. IF YOU DO NOT FILE A WRITTEN ANSWER OR OTHER WRITTEN
RESPONSIVE PLEADING TO THIS NOTICE OF HEARING ON OR BEFORE
THE 20TH DAY AFTER THE DATE ON WHICH THIS NOTICE WAS MAILED TO
YOU OR PERSONALLY SERVED ON YOU, THE FACTUAL ALLEGATIONS IN
THIS NOTICE COULD BE DEEMED ADMITTED, AND THE SECURITIES
COMMISSIONER MAY DISPOSE OF THIS CASE WITHOUT A HEARING AND
MAY GRANT THE RELIEF SOUGHT IN THIS NOTICE. THE RESPONSE MUST
BE FILED IN AUSTIN, TEXAS, WITH THE SECURITIES COMMISSIONER AND
THE STATE OFFICE OF ADMINISTRATIVE HEARINGS, AND ALSO SERVED
ON THE STAFF OF THE STATE SECURITIES BOARD. IF YOU FAIL TO
ATTEND THE HEARING, EVEN IF A WRITTEN ANSWER OR OTHER
RESPONSIVE PLEADING HAS BEEN FILED AND SERVED, THE FACTUAL
ALLEGATIONS IN THIS NOTICE COULD BE DEEMED ADMITTED, AND THE
SECURITIES COMMISSIONER MAY DISPOSE OF THIS CASE WITHOUT A
HEARING AND MAY GRANT THE RELIEF SOUGHT IN THIS NOTICE.
Notice of Hearing/Celsius Network, Inc., et al./Page 9
49. PARTIES THAT ARE NOT REPRESENTED BY AN ATTORNEY MAY OBTAIN
INFORMATION REGARDING CONTESTED CASE HEARINGS ON THE
PUBLIC WEBSITE OF THE STATE OFFICE OF ADMINISTRATIVE HEARINGS
AT WWW.SOAH.TEXAS.GOV, OR IN PRINTED FORMAT UPON REQUEST TO
THE STATE OF ADMINISTRATIVE HEARINGS.
50. Respondents may access the Securities Act and the Board Rules through the
website of the State Securities Board at www.ssb.texas.gov. Respondents may
also access the SOAH Rules through the website of the State Office of
Administrative Hearings at www.soah.texas.gov and the Administrative Procedure
Act through Texas Legislature Online at statutes.capitol.texas.gov.
51. The Securities Act authorizes the Texas State Securities Board to pursue
administrative, civil, or criminal enforcement cases. The Securities Act and Board
Rules also authorize the Texas State Securities Board to share information with
and refer cases to other governmental agencies with administrative, civil, or
criminal jurisdiction. These other governmental agencies include, without
limitation, state and federal regulatory agencies, law enforcement agencies and
prosecutors’ offices. Therefore, any information provided, filed, or otherwise
supplied by Respondents may be shared with these other government agencies
and/or used in other cases. Whether the Texas State Securities Board makes its
files available to other governmental agencies or refers cases to other government
agencies is typically confidential pursuant to Section 28 of the Texas Securities
Act.
52. Pursuant to Board Rule 105.13, the Enforcement Division is now respectfully
requesting and will continue to respectfully request the State Office of
Administrative Hearings order all costs charged to the Texas Securities Board by
any court reporting service be assessed against Respondents.
53. Persons with disabilities who need special accommodations at the hearing,
whether held at the State Office of Administrative Hearings or through an audio or
video conferencing platform, should contact the Docketing Department of the State
Office of Administrative Hearings at 512-475-4993 at least one week prior to the
hearing.
CONTACT AND FILING INFORMATION
54. The Enforcement Division is represented by Rachel Anderson Rynders, Attorney,
Enforcement Division. Ms. Anderson Rynders’ State Bar Card Number is
24103132, her work address 208 E. 10th Street, 5th Floor, Austin, Texas 78701,
her telephone number is 512-305-8392, her facsimile number is 512-355-0404,
and her email address is [email protected].
Notice of Hearing/Celsius Network, Inc., et al./Page 10
55. The Docketing Office of the State Office of Administrative Hearings is located at
300 W. 15th Street, Austin, Texas 78701, and it may be contacted by telephone at
512-745-3445 and by facsimile at 512-475-4994.
56. The State Office of Administrative Hearings may conduct the hearing via audio or
video conferencing. The audio and video conferencing platforms are secure, free
meetings held telephonically or through the internet. The State Office of
Administrative Hearings will provide instructions for all hearings held telephonically
or through a video conferencing platform.
57. Persons with disabilities who need special accommodations at the hearing,
whether held at the State Office of Administrative Hearings or through an audio or
video conferencing platform, should contact the Docketing Department of the State
Office of Administrative Hearings at 512-475-4993 at least one week prior to the
hearing.
58. Pursuant to Board Rule 105.8, all documents filed by any party, other than
business records and transcripts, must be contemporaneously served upon
Marlene Sparkman, General Counsel and Securities Commissioner's
Representative. Ms. Sparkman’s address is 208 E. 10th Street, 5th Floor, Austin,
Texas 78701, her telephone number is 512-305-8300, her facsimile number is 512-
305-8336, and her email address is [email protected].
Signed on this, the 17th day of September
2021
By: /s/ Joe Rotunda
Joe Rotunda
State Bar No. 24029808
Division Director, Enforcement Division
Texas State Securities Board
208 E. 10th Street, 5th Floor
Austin, Texas 78701
T: 512-305-8392
F: 512-355-0404
CERTIFICATE OF SERVICE
I hereby certify that on this, the 17th day of September 2021, true and correct copies of
this Notice of Hearing are being served on the following parties through the means set
forth below:
Notice of Hearing/Celsius Network, Inc., et al./Page 11
MARLENE SPARKMAN
General Counsel for the State Securities Board and the Securities Commissioner’s
Representative, is being served by electronic mail addressed to
CELSIUS NETWORK INC.
Service by (1) certified mail, return receipt requested, addressed to 221 River Street, 9th
Floor, Hoboken, New Jersey 07030; (2) certified mail, return receipt requested, addressed
to The Harley Building, 77-79 New Cavendish Street, London W1W 6XB, United
Kingdom; (3) certified mail, return receipt requested, addressed to its counsel John
Sikora, Jr., Partner, Latham & Watkins LLP, 330 North Wabash Avenue, Suite 2800,
Chicago, Illinois 60611; and (4) electronic mail to its counsel, John Sikora, Jr., at
CELSIUS NETWORK LIMITED
Service by (1) certified mail, return receipt requested, addressed to 221 River Street, 9th
Floor, Hoboken, New Jersey 07030; (2) certified mail, return receipt requested, addressed
to The Harley Building, 77-79 New Cavendish Street, London W1W 6XB, United
Kingdom; (3) certified mail, return receipt requested, addressed to its counsel John
Sikora, Jr., Partner, Latham & Watkins LLP, 330 North Wabash Avenue, Suite 2800,
Chicago, Illinois 60611; and (4) electronic mail to its counsel, John Sikora, Jr., at
CELSIUS US HOLDING, LLC
Service by (1) certified mail, return receipt requested, addressed to 221 River Street, 9th
Floor, Hoboken, New Jersey 07030; (2) certified mail, return receipt requested, addressed
to The Harley Building, 77-79 New Cavendish Street, London W1W 6XB, United
Kingdom; (3) certified mail, return receipt requested, addressed to its counsel John
Sikora, Jr., Partner, Latham & Watkins LLP, 330 North Wabash Avenue, Suite 2800,
Chicago, Illinois 60611; and (4) electronic mail to its counsel, John Sikora, Jr., at
CELSIUS NETWORK, LLC
Service by (1) certified mail, return receipt requested, addressed to 221 River Street, 9th
Floor, Hoboken, New Jersey 07030; (2) certified mail, return receipt requested, addressed
to The Harley Building, 77-79 New Cavendish Street, London W1W 6XB, United
Kingdom; (3) certified mail, return receipt requested, addressed to its counsel John
Sikora, Jr., Partner, Latham & Watkins LLP, 330 North Wabash Avenue, Suite 2800,
Chicago, Illinois 60611; and (4) electronic mail to its counsel, John Sikora, Jr., at
CELSIUS LENDING, LLC
Service by (1) certified mail, return receipt requested, addressed to 221 River Street, 9th
Floor, Hoboken, New Jersey 07030; (2) certified mail, return receipt requested, addressed
to The Harley Building, 77-79 New Cavendish Street, London W1W 6XB, United
Notice of Hearing/Celsius Network, Inc., et al./Page 12
Kingdom; (3) certified mail, return receipt requested, addressed to its counsel John
Sikora, Jr., Partner, Latham & Watkins LLP, 330 North Wabash Avenue, Suite 2800,
Chicago, Illinois 60611; and (4) electronic mail to its counsel, John Sikora, Jr., at
By: /s/ Joe Rotunda
Joe Rotunda
State Bar No. 24029808
Director, Enforcement Division
Texas State Securities Board
208 E. 10th Street, 5th Floor
Austin, Texas 78701
T: 512-305-8392
F: 512-355-0404
