SEC v. Punch TV: Collins Liability Ruling and $0 Disgorgement

In SEC v. Punch TV Studios, Inc., the Securities and Exchange Commission sued the Santa Fe Springs television company and its founder and CEO, Joseph Collins, in September 2021 for selling more than $1.2 million in unregistered stock to nearly 700 investors after the SEC had already suspended the company’s ability to do so. The case ended with a split result: a permanent injunction against future violations, but zero dollars awarded on the SEC’s demand for roughly $1.35 million in disgorgement and prejudgment interest. The docket was formally closed on April 8, 2025.¹

What the SEC Alleged

Punch TV Studios was incorporated in 2014 and described itself as a television production company focused on film, animation, and children’s and family programming.² By December 2020, according to the SEC, the company had no employees other than Collins, no revenue, no licensed content, and no production or broadcasting activity.³ Collins nevertheless solicited investors through the company website, social media, cold calls, and a YouTube video titled “Why Punch TV Studios will make a Billion Dollars.”⁴

The complaint, filed in the U.S. District Court for the Central District of California and assigned to Judge Andre Birotte Jr., charged violations of Sections 5(a) and 5(c) of the Securities Act of 1933, the provisions requiring that securities offerings be registered or fall within a valid exemption.¹ The SEC labeled Collins and the company as recidivists and said the failure to register had “deprived investors of meaningful information” about the company’s financial condition and prospects.³ Notably, the SEC did not allege fraud, misuse of funds, or specific investor losses.

The 2018 Suspension the Offerings Ignored

The “recidivist” label traced back to an earlier proceeding. Punch TV had qualified a Regulation A offering in 2016 and raised at least $3 million from roughly 6,600 investors before the SEC discovered that the financial statements had not been audited by a qualified CPA and that required periodic reports had not been filed. On January 9, 2018, the SEC entered a suspension order that halted the offering for nine months and temporarily revoked the Regulation A exemption. To resume selling, Punch TV had to file a post-qualification amendment or a new Form 1-A and obtain SEC qualification. It never did.⁴

Instead, according to the SEC, Collins launched two new offerings. Between January 2018 and June 2020, Punch TV sold common stock at $1 per share, purporting to rely on the same Regulation A exemption that had just been suspended, and raised approximately $681,924 from more than 660 investors. A parallel offering at $5 per share, running from March 2018 to April 2019, brought in at least $519,230 from about 28 investors and claimed a Regulation D exemption. The SEC alleged that Collins had not verified whether the Regulation D investors were accredited and had used general solicitation methods that disqualified the offering from that exemption.⁴

What the SEC Asked the Court For

The agency sought a permanent injunction against future Section 5 violations, disgorgement of the funds raised plus prejudgment interest, civil penalties, and a penny stock bar preventing Collins and the company from participating in penny stock offerings.² The disgorgement demand came to approximately $1.2 million, with roughly $130,000 in prejudgment interest on top.⁵

The Liability Ruling

On June 30, 2023, the SEC moved for partial summary judgment on liability. After a September 1 hearing, Judge Birotte granted the motion on September 6, 2023, finding that both Punch TV and Collins had violated Section 5 of the Securities Act, and entered a permanent injunction against future violations.¹ The question of monetary remedies was left for a later phase of the case.

Why the Court Awarded $0 in Disgorgement

Shortly after the liability ruling, Collins’ defense counsel withdrew, and the November 2023 trial date was vacated. Collins later obtained new representation from the Investor Choice Advocates Network, a nonprofit litigation group founded by former SEC senior trial counsel Nicolas Morgan, with Ed Totino of Baker McKenzie as pro bono co-counsel.⁶

ICAN’s remedies-phase defense turned on the Supreme Court’s decision in Liu v. SEC. The defense argued that Liu limits the SEC’s disgorgement power to situations where recovered funds can be returned to actual victims rather than deposited with the U.S. Treasury, and that no fraud, misuse of investor money, or investor losses had been alleged in the Punch TV case. On that reading, ordering disgorgement of the offering proceeds would go beyond the boundaries the Supreme Court had drawn.⁵

In September 2024, Judge Birotte rejected the SEC’s monetary claims entirely, awarding $0 in disgorgement and $0 in prejudgment interest. According to ICAN, the court declined to extend the SEC’s disgorgement authority beyond the limits set in Liu.⁵

What the Final Judgment Left in Place

The permanent injunction entered in September 2023 remained. Collins and Punch TV Studios are barred from future violations of Sections 5(a) and 5(c) of the Securities Act, meaning they cannot offer or sell unregistered securities absent a valid exemption. The SEC obtained a judicial finding that the securities laws had been broken and a court order preventing repetition, but recovered none of the roughly $1.35 million it had sought. The case was terminated on April 8, 2025.¹

1
CourtListener. SEC v. Punch TV Studios Inc., Docket
2
SEC.gov. SEC Charges Punch TV Studios and Joseph Collins
3
Whittier Daily News. Santa Fe Television Studio With Just 1 Employee, No Revenues, Targeted by SEC
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SEC.gov. SEC Complaint, SEC v. Punch TV Studios Inc.
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ICAN Law. Celebrating Our First Victory: SEC v. Punch TV
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ICAN Law. Cases: SEC v. Punch TV