UNITED STATES OF AMERICA
before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
Release No. 102059 / December 31, 2024
Admin. Proc. File No. 3-22322
In the Matter of
SEVEN NETWORKS, INC. (N/K/A SEVEN NETWORKS,
LLC)
ORDER TO SHOW CAUSE
On November 13, 2024, the Securities and Exchange Commission issued an order
instituting proceedings (“OIP”) against Seven Networks, Inc. (n/k/a Seven Networks, LLC)
(“Respondent”) pursuant to Section 12(j) of the Securities Exchange Act of 1934.1 On
November 26, 2024, the Division of Enforcement filed a Declaration of Gina Joyce, which
established that, pursuant to Commission Rule of Practice 141(a)(2)(ii),2 service of the OIP was
made on Respondent on November 25, 2024.3
As stated in the OIP, Respondent’s answer was required to be filed within ten days after
service of the OIP.4 As of the date of this order, Respondent has not filed an answer. The
prehearing conference and hearing are thus continued indefinitely.
Accordingly, Respondent is ORDERED to SHOW CAUSE by January 17, 2025, why the
registration of its securities should not be revoked by default due to its failure to file an answer or
otherwise to defend this proceeding. Respondent’s submission shall address the reasons for its
1 Seven Networks, Inc., Exchange Act Release No. 101608, 2024 WL 4773016 (Nov. 13,
2023).
2 17 C.F.R. § 201.141(a)(2)(ii).
3 The Division’s service declaration states that service of the OIP was made to the address
on Respondent’s most recent filing with the Commission, which the Division alleges was a Form
8-A12G filed on May 10, 2004. But Respondent’s most recent filing with the Commission was
in fact a Form D filed in January 2007. This discrepancy does not matter in this case, however,
because the address listed on the Respondent’s Form D matches the address listed in the
Division’s service declaration.
4 Seven Networks, 2024 WL 4773016, at *2; Rules of Practice 151(a), 160(b), 220(b),
17 C.F.R. §§ 201.151(a), 201.160(b), 201.220(b). 2
failure to timely file an answer and include a proposed answer to be accepted in the event that the
Commission does not enter a default against Respondent. When a party defaults, the allegations
in the OIP may be deemed to be true and the Commission may determine the proceeding against
that party upon consideration of the record without holding a public hearing.
If Respondent fails to respond to this order to show cause, it may be deemed in default,
the proceeding may be determined against it, and the registration of its securities may be
revoked.5 Upon review of the filings in response to this order, the Commission will either direct
further proceedings by subsequent order or issue a final order resolving the matter.
The parties’ attention is directed to the e-filing requirements in the Rules of Practice.6
We also remind the parties that any document filed with the Commission must be served upon all
participants in the proceeding and be accompanied by a certificate of service.7
For the Commission, by the Office of the General Counsel, pursuant to delegated
authority.
Vanessa A. Countryman
Secretary
5 Rules of Practice 155, 180, 17 C.F.R. §§ 201.155, 201.180; see Seven Networks, 2024
WL 4773016, at *2 (“If Respondent fails to file the directed Answer, . . . [it] may be deemed in
default and the proceedings may be determined against [it] . . . .”).
6 See Rules of Practice 151, 152(a), 17 C.F.R. §§ 201.151, .152(a) (providing procedure for
filing papers with the Commission and mandating electronic filing in the form and manner
posted on the Commission’s website); Instructions for Electronic Filing and Service of
Documents in SEC Administrative Proceedings and Technical Specifications,
https://www.sec.gov/efapdocs/instructions.pdf. Parties generally also must certify that they have
redacted or omitted sensitive personal information from any filing. Rule of Practice 151(e),
17 C.F.R. § 201.151(e).
7 See Rule of Practice 150, 17 C.F.R. § 201.150 (generally requiring parties to serve each
other with their filings); Rule of Practice 151(d), 17 C.F.R. § 201.151(d) (“Papers filed with the
Commission . . . shall be accompanied by a certificate stating the name of the person or persons
served, the date of service, the method of service, and the mailing address or email address to
which service was made, if not made in person.”).
