The allegations read: The securities and exchange commission ("commission") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted against robert seropian ("seropian" or "respondent"). In anticipation of the institution of these proceedings, respondent has submitted an offer of settlement which the commission has determined to accept. The commission finds that these proceedings arise out of unregistered broker activity by respondent robert seropian-a sales agent for straightpath venture partners llc ("straightpath") who solicited investments in unregistered membership interests in limited liability companies (the "straighpath funds"), each of which purpotedly owned shares of private issuers that had prospects of becoming publicly-traded issuers ("pre-ipo shares"). Seropian successfully solicited more than $11.5 million in investments in the straightpath funds from at least 42 investors. Through his unregistered conduct brokering transactions between these investors and the straightpath funds, seropian obtained $1,217,922.44 in transaction-based compensation.