Page 1 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v.
No. 1:23-cv-01599-ABJ-ZMF
BINANCE HOLDINGS LIMITED,
BAM TRADING SERVICES INC.,
BAM MANAGEMENT US HOLDINGS INC.,
AND CHANGPENG ZHAO,
Defendants.
DECLARATION OF MATTHEW BEVILLE
I, MATTHEW BEVILLE, declare pursuant to 28 U.S.C. § 1746 as follows:
1.
I am an attorney of the law firm Wilmer Cutler Pickering Hale & Dorr LLP,
Pennsylvania Ave., NW, Washington, DC 20037. I am counsel to Defendants BAM Trading
Service, Inc. (“BAM Trading”) and BAM Management US Holdings Inc. (“BAM Management,”
together with BAM Trading, “BAM”). I submit this declaration in support of BAM’s Motion to
Dismiss.
2.
I have personal knowledge of the matters set forth in this declaration, and if called
as a witness, I could and would competently testify under oath to the facts stated herein.
3.
A true and correct copy of BAM’s Trading Rules, last updated in September 2019,
is attached as Exhibit 1. See Compl. ¶¶ 233, 244–45.
4.
On November 20, 2019, CoinDesk hosted a webinar titled “Crypto Exchanges,
Markets and Liquidity Webinar” (the “CoinDesk Webinar”). Catherine Coley (BAM Trading’sPage 2 then-CEO) was a guest on the CoinDesk Webinar. A true and correct copy of a transcript of the
CoinDesk Webinar is attached as Exhibit 2. See id. ¶ 246.
5.
A true and correct excerpt of BAM’s July 2021 Trade Surveillance Manual is
attached as Exhibit 3. See id. ¶ 249.
6.
A true and correct excerpt of BAM’s September 2021 Seed Round Pitch Deck is
attached as Exhibit 4. See id. ¶¶ 248, 256–57, 265.
7.
A true and correct copy of BAM’s Terms of Use, which was operative when the
Complaint was filed, is attached as Exhibit 5. See id. ¶¶ 126, 153, 244, 346.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 21st day of September, 2023.
/s/ Matthew Beville
Matthew Beville
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Case 1:23-cv-01599-ABJ-ZMF Document 117-2 Filed 09/21/23 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
SECURITIES AND EXCHANGE COMMISSION,
Plaintiff,
v.
No. 1:23-cv-01599-ABJ-ZMF
BINANCE HOLDINGS LIMITED,
BAM TRADING SERVICES INC.,
BAM MANAGEMENT US HOLDINGS INC.,
AND CHANGPENG ZHAO,
Defendants.
DECLARATION OF MATTHEW BEVILLE
I, MATTHEW BEVILLE, declare pursuant to 28 U.S.C. § 1746 as follows:
1.
I am an attorney of the law firm Wilmer Cutler Pickering Hale & Dorr LLP, 2100
Pennsylvania Ave., NW, Washington, DC 20037. I am counsel to Defendants BAM Trading
Service, Inc. (“BAM Trading”) and BAM Management US Holdings Inc. (“BAM Management,”
together with BAM Trading, “BAM”). I submit this declaration in support of BAM’s Motion to
Dismiss.
2.
I have personal knowledge of the matters set forth in this declaration, and if called
as a witness, I could and would competently testify under oath to the facts stated herein.
3.
A true and correct copy of BAM’s Trading Rules, last updated in September 2019,
is attached as Exhibit 1. See Compl. ¶¶ 233, 244–45.
4.
On November 20, 2019, CoinDesk hosted a webinar titled “Crypto Exchanges,
Markets and Liquidity Webinar” (the “CoinDesk Webinar”). Catherine Coley (BAM Trading’s
PDF Page 3
Case 1:23-cv-01599-ABJ-ZMF Document 117-2 Filed 09/21/23 Page 2 of 2
then-CEO) was a guest on the CoinDesk Webinar. A true and correct copy of a transcript of the
CoinDesk Webinar is attached as Exhibit 2. See id. ¶ 246.
5.
A true and correct excerpt of BAM’s July 2021 Trade Surveillance Manual is
attached as Exhibit 3. See id. ¶ 249.
6.
A true and correct excerpt of BAM’s September 2021 Seed Round Pitch Deck is
attached as Exhibit 4. See id. ¶¶ 248, 256–57, 265.
7.
A true and correct copy of BAM’s Terms of Use, which was operative when the
Complaint was filed, is attached as Exhibit 5. See id. ¶¶ 126, 153, 244, 346.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 21st day of September, 2023.
/s/ Matthew Beville
Matthew Beville
2
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