On May 19, 2016, the Commission filed a complaint (the “Complaint”) against David B. Kaplan, Esq. (“Kaplan”), Synchronized Organizational Solutions, LLC (“SOS”), Synchronized Organizational Solutions International, Ltd. (“SOSI”), and Manna International Enterprises, Inc (“Manna Int’l”). (collectively, the “Defendants”), as well as relief defendants Lisa M. Kaplan (“L. Kaplan”), The Walking-Water Foundation (“WWF”), and Manna Investments, LLC (“Manna”) (collectively, the “Relief Defendants”). The Complaint alleged that, from at least May 1, 2012, to the filing of the complaint, the Defendants violated federal securities laws by making material misrepresentations to investors and perpetrating a fraudulent scheme. Kaplan, by and through SOSI, offered investments in a purported off-shore investment program. He received investor funds, by and through SOS and Manaa Int’l, for the program, and misappropriated a portion of these funds by transferring them to other accounts he controlled, using them for personal benefit, making Ponzi-like payments to other investors, and transferring them to the Relief Defendants. See Complaint.

On January 8, 2018, the Defendants were ordered to pay a total of $8,120,042.48 in disgorgement, prejudgment interest, and penalty to the Commission. The Court also ordered L. Kaplan to pay $340,764.75 in disgorgement and $26,762.65 in prejudgment interest; WWF to pay $599,012.34 in disgorgement and $45,363.74 in prejudgment interest; and Manna to pay $483,417.52 in disgorgement and $38,119.61 in prejudgment interest to the Commission. The Commission was ordered to hold all funds, together with interest and income earned thereon (collectively, the “Fund”), pending further order of the Court. See Defendants’ Final Judgment, L. Kaplan’s Final Judgment, WWF’s Final Judgment, Manna’s Final Judgment.

The Fund consists of $1,129,477.03, and any future funds paid pursuant to the Defendants judgment(s) will be added to the Fund: however, at this time, the SEC is not expecting additional funds to be collected.

On February 20, 2024, the Court entered an order that appointed Miller Kaplan Arase LLP as the Tax Administrator to fulfill the tax obligations of the Fund.See The Court’s Order.

On April 30, 2024, the Commission filed a Motion to appoint Rust Consulting as the Distribution Agent to oversee the administration and distribution of the Fund to harmed investors. See the Commission’s Motion.