MEMORANDUM AND ORDER
RICHARD J. SULLIVAN, District Judge.
Plaintiff Securities and Exchange Commission (the "SEC") brings this action against Defendants Elek Straub, Andras Balogh, and Tamas Morvai (collectively, "Defendants") — executives of the Hungarian telecommunications company Magyar Telekom, Plc. ("Magyar") — arising out of alleged violations of the Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1,
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