Ms. Cochran’s complaint in this case asserts her right not to be forced, without her consent, to participate in adjudicative proceedings conducted by an ALJ who lacks proper constitutional authority. She is not challenging the SEC’s general authority to prosecute her or to seek sanctions for the securities law violations she is alleged to have committed. Nor is she questioning in her complaint the merits of the SEC’s claims or the severity of the sanctions that could be imposed against her, although she has asserted defenses to those claims in the pending SEC administrative proceeding.

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