When a text message arrived at 9:25 on the night of May 9, 2023, Caroline J. Campbell, 47, of Watsonville, California, also known as Caroline Campbell Knapic and Caroline Harrison, was a documentary filmmaker employed by ImmunityBio, Inc. to film interviews with doctors and patients in support of the anticipated commercial launch of Anktiva, the company’s immunotherapy for bladder cancer. Campbell had built a credible career in the field. She studied zoology at the University of Edinburgh, worked for the BBC Natural History Unit and National Geographic, co-produced the Wildscreen Planet Earth award-winning documentary Global Dimming, and in 2010 founded The Hive Studios, a San Francisco-based production company whose clients have included Nike, Google, and Capital One, specializing in branded documentaries and purpose-driven marketing.
The ImmunityBio work was exactly the kind of assignment her company was built for. The text came from a colleague at an affiliated company: “You awake? Change in plans.” The call that followed lasted three minutes. At 9:46 p.m., Campbell placed an online order to sell 44,495 shares of ImmunityBio common stock, just 21 minutes after the text arrived. The next morning she called her investment adviser and instructed him to sell every remaining ImmunityBio share she owned. When challenged by investigators, she offered three separate explanations for her trading, each contradicted by the record. On April 6, 2026, the SEC issued an administrative cease-and-desist order requiring Campbell to pay $332,263.53 in disgorgement, interest, and civil penalties for insider trading in violation of Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder.
The Drug Campbell Was Promoting and Why the FDA’s Decision Mattered So Much
ImmunityBio, founded by billionaire Patrick Soon-Shiong, had no FDA-approved products as of May 2023. Anktiva, a first-in-class IL-15 agonist immunotherapy, was the company’s entire commercial bet. The FDA had accepted the application in July 2022 with a targeted action date of May 23, 2023. Campbell had been a contractor at ImmunityBio since August 2018 before becoming a full employee in August 2022. Her IMDb page credits include the documentaries The Art of Life, The Wisdom of Trauma, and Where Olive Trees Weep, all produced in collaboration with SAND during the pandemic years. In the days leading up to May 9, she was coordinating interviews with a scientist and an ImmunityBio executive for promotional materials tied to the anticipated Anktiva launch. She had planned to travel from Northern California to the Los Angeles area on May 10 and 11 to conduct those interviews.
On the morning of May 9, 2023, the FDA delivered a Complete Response Letter to ImmunityBio informing the company it would not approve Anktiva by May 23 and requesting additional information about the third-party manufacturing process. The news traveled through ImmunityBio’s management structure that evening. A management meeting discussed the substance of the letter. An ImmunityBio affiliate employee who worked alongside Campbell on the Anktiva promotional materials was copied on an internal email at 9:55 p.m. with the subject line “Internal note re: FDA news,” nine minutes after Campbell had already placed her sell order. That nine-minute gap, and the three-minute phone call that preceded it, define the case.
The Trade, the Follow-Up Call, and the Text That Said “Please Do Not Tell Anyone”
The SEC’s order reconstructs the evening with documentary precision. At 9:25 p.m., the affiliate employee texted Campbell asking if she was awake, then called without waiting for a reply. The two spoke for approximately three minutes. At 9:46 p.m., Campbell placed her sell order at Brokerage Firm 1 for 44,495 shares, nearly all of her holdings there. At 7:00 the following morning, she called her investment adviser and instructed him to liquidate every ImmunityBio share in her second brokerage account. The adviser misunderstood and sold only 4,000 of her 10,000 shares. Campbell later admitted to ImmunityBio’s general counsel that she had intended to sell everything.
At 11:20 a.m. on May 10, the same affiliate employee texted Campbell: “Please do not tell anyone about the FDA.” Campbell replied within seconds: “Ok,” and then, “For sure!” That was the first and only communication between them since the late-night call. That evening, having realized she had not fully liquidated her Brokerage Firm 1 position, Campbell placed an additional sell order for 2,459 shares, but this order did not execute until the morning of May 11, after ImmunityBio publicly disclosed the Complete Response Letter. ImmunityBio’s stock opened that day at $2.76, down approximately 55 percent from the prior close of $6.22. By selling 48,495 shares before that disclosure, Campbell avoided losses of $157,066.28.
Three Explanations, None of Them True
When Brokerage Firm 1 contacted Campbell on June 27, 2023 to ask about her trading around the Complete Response Letter disclosure, she told the broker representative she had sold as part of a standing investment strategy: she would buy into companies awaiting FDA decisions on drugs or therapies and then sell before the actual outcome was announced. She said she knew only former ImmunityBio employees and provided no names when asked. She initially identified herself as working for the umbrella entity rather than ImmunityBio directly. All three elements were false. She was an ImmunityBio employee at the time of the call, she knew current employees including the one who had called her at 9:25 p.m., and she had no documented history of a sell-before-outcome investment strategy.
When ImmunityBio’s general counsel interviewed her on August 25, 2023, Campbell offered a different explanation entirely: she had sold her shares because she felt guilty about making money from the stock as it rose and wanted to exit her position. She also claimed she had disclosed her ImmunityBio employment to the Brokerage Firm 1 representative, a claim directly contradicted by the broker’s own account of that conversation. The SEC’s order documents both interviews and finds the trading was based on material nonpublic information, conducted without the pre-clearance required by ImmunityBio’s insider trading policy, and executed during a quarterly blackout period Campbell had agreed in writing to observe when she became a full employee in August 2022.
What the Order Requires and Where ImmunityBio Stands Now
The April 6, 2026 cease-and-desist order requires Campbell to pay disgorgement of $157,066.28, prejudgment interest of $18,130.97, and a civil money penalty of $157,066.28, totaling $332,263.53 payable in four installments over 365 days. All amounts are directed to the U.S. Treasury. The order permanently bars Campbell from future violations of Section 10(b) and Rule 10b-5. No criminal charges have been announced. The ImmunityBio colleague who texted “Change in plans” and “Please do not tell anyone about the FDA” is identified only as an employee of an affiliated company and is not named as a respondent in this proceeding.
The Anktiva whose rejection Campbell traded on was eventually approved by the FDA in April 2024, after ImmunityBio addressed the manufacturing deficiencies cited in the Complete Response Letter. By March 2026, ImmunityBio and its billionaire executive chairman Patrick Soon-Shiong were facing a new FDA warning letter for false and misleading promotional claims about Anktiva, including Soon-Shiong’s podcast statement that the drug “actually can treat all cancers,” which wiped out more than $2 billion in market capitalization in a single session. The promotional filmmaker who had been building the launch campaign for Anktiva had already been gone from the company for nearly three years.
Conclusion
Campbell’s liability of $332,263.53 covers the losses she avoided plus a matching civil penalty, structured as four equal installments. The case turns on 21 minutes, three minutes of phone conversation, and the gap between what she told two separate investigators and what the brokerage records showed. The facts make the irony unavoidable: Campbell was filming the promotional interviews meant to celebrate Anktiva’s approval at the exact moment she was trading on knowledge that approval had been denied.
