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Of the $4,473,828,306 that Terraform Labs and Kwon must pay to the SEC in disgorgement, prejudgment interest, and civil penalties, Kwon must pay at least $204,320,196 out of his own pocket. The steep penalty is slightly lower than the SEC’s first settlement offer of $5.3 billion in fines, but much higher than the virtual slap on the wrist – a $1 million civil penalty and no disgorgement or injunctions – Terraform Labs suggested to the court in its April memorandum of opposition to the SEC’s motion for final judgment.