Paul W. Jorgensen, 55, the former Chief Revenue Officer of Doximity, Inc., a digital platform serving U.S. medical professionals, traded company stock on insider knowledge not once but twice, and on both occasions the information he acted on was the same: Doximity’s sales were coming in below expectations and he knew it before the public did. In August 2022, while still holding the CRO title, he sold 61,162 shares of Doximity stock ahead of a quarterly earnings call, avoiding losses tied to the weak results about to be disclosed. He also failed to file the reports the law requires executives to submit when they sell company shares.
Approximately one year later, days after being terminated from the company, he traded again, this time with knowledge not only of poor sales but also of a planned reduction in force at Doximity. Together, the two rounds of trading produced aggregate profits and losses avoided of approximately $2,532,775. On March 16, 2026, the SEC filed settled charges against Jorgensen in the Southern District of New York. He had already pleaded guilty to securities fraud in a parallel criminal action on January 9, 2026, and is awaiting sentencing.
A Quarterly Earnings Call in 2022 Was the First Trade and the First Failure to Report
In August 2022, Doximity was approaching a scheduled quarterly earnings release. Jorgensen, as Chief Revenue Officer, had access to internal sales data that had not been disclosed to the market. That data showed the company’s sales were coming in below what analysts and investors expected. Before the earnings call went public, Jorgensen sold 61,162 shares of Doximity stock, locking in a price that reflected the market’s still-uninformed expectations rather than the reality he already knew.
The trade itself was the first violation. The second was what followed. Section 16(a) of the Securities Exchange Act of 1934 requires officers of public companies to publicly disclose their stock transactions within two business days. According to the SEC’s complaint, Jorgensen failed to file the required reports disclosing these sales, leaving investors without the transparency the law specifically mandates for corporate insiders.
Terminated from Doximity, He Traded Again Before the Next Earnings Call
Roughly a year after the first round of trading, Jorgensen was terminated from Doximity. What followed in the days after his termination reflects a pattern the SEC has seen in other insider trading cases involving departing executives: the belief that separation from the company removes the obligation to protect its confidential information.
It does not. Days after being let go, and before Doximity’s next earnings call, Jorgensen again traded Doximity securities based on material nonpublic information. This time the information was broader than weak quarterly sales figures. He had knowledge of the underperformance of the company’s sales team and of a planned reduction in force. A layoff announcement is among the most market-sensitive disclosures a company can make, and trading on advance knowledge of one while still possessing the company’s confidential information is a straightforward securities violation regardless of employment status at the time of the trade.
Two Rounds of Trading Produced $2.5M in Profits and Losses Avoided
The SEC’s complaint charges Jorgensen with violating Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5, the core antifraud provisions covering insider trading, as well as Section 16(a) and Rule 16a-3 for his failure to file the required ownership reports after the 2022 trades. The aggregate financial benefit across both rounds of trading came to approximately $2,532,775 in profits and losses avoided.
Jorgensen consented to the entry of judgment, subject to court approval, agreeing to a permanent injunction against future violations of the charged provisions and a permanent bar from serving as an officer or director of any public company. Under the terms of a bifurcated settlement, the precise amounts of disgorgement, prejudgment interest, and civil penalty will be determined by the court upon motion by the SEC. The investigation was conducted by Randall Friedland, Ann Rosenfield, Patrick McCluskey, and Kevin Gershfeld, supervised by Brian Quinn and Michael Brennan. Litigation is being led by Christopher Carney under the supervision of James Carlson.
A Guilty Plea in January 2026 Preceded the SEC’s Civil Filing by Months
The criminal case moved ahead of the civil action. On January 9, 2026, Jorgensen pleaded guilty to securities fraud in a parallel criminal proceeding brought by the U.S. Attorney’s Office for the Southern District of New York. The SEC’s civil complaint followed on March 16, 2026. Jorgensen is currently awaiting sentencing in the criminal matter. The SEC credited assistance from the U.S. Attorney’s Office, the Federal Bureau of Investigation, and the Financial Industry Regulatory Authority in building the case.
Conclusion
The Jorgensen case involves a pattern the SEC treats as particularly serious: an executive who trades on inside information, fails to comply with mandatory disclosure requirements, is removed from his position, and then trades again on information he was never entitled to use in the market. The termination did not reset his obligations. The second trade, made days after leaving Doximity with knowledge of a planned workforce reduction, extended his exposure considerably beyond the original 2022 violation. With a guilty plea already entered, the remaining question is the length of his criminal sentence and the final dollar figure the court assigns to disgorgement and penalties on the civil side.
