Louis Lehot-The Violation

According to the SEC complaint, Office Depot’s CEO and then-CFO were concerned that analyst estimates for the then current quarter were too high. They considered issuing a press release to provide the company’s lower internal guidance, but were concerned because internal estimates were incomplete at that point. Instead, they directed employees to conduct one-on-one calls with analysts designed to cause analysts to revise their estimates downward by referring to recent public statements of comparable companies that cautioned of the slowing economy’s impact on earnings.

Louis Lehot-The Violation