| http://www.w3.org/ns/prov#value | - Finally, the Respondent argues that a cease and desist order is a penalty akin to a civil penalty, and thus the five-year statute of limitations applies pursuant to Johnson v. SEC. The Commission recently granted a motion to dismiss a proceeding that included a cease and desist order by a respondent who argued that the proceeding was time-barred pursuant to Johnson v. SEC. Richard M. Kulak, 64 SEC
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