The SEC alleges that the defendants diverted millions of dollars of investor funds to make Ponzi payments and to pay undisclosed sales commissions to themselves and others.

According to the SEC’s complaint, filed on Dec. 11, 2023, in the U.S. District Court for the Northern District of Texas and unsealed on Dec. 13, the defendants have raised at least $191 million from more than 2,100 investors in at least 15 states by offering and selling investments related to the supposed purchase and sale of cattle.

The defendants told investors that Agridime would use their funds to acquire, feed, and raise cattle on its network of ranches, and investors would help provide “fellow Americans with the highest quality farm fresh beef available.” However, as alleged in the complaint, the defendants did not purchase nearly enough cattle or generate sufficient revenues from cattle operations to deliver the promised returns. Instead, the complaint alleges that, since December 2022, the defendants have used at least $58 million of new investor funds to make Ponzi payments to prior investors and more than $11 million to pay undisclosed sales commissions to Wood, Link, Link’s wife, and other Agridime sales representatives.  

The SEC’s complaint charges the defendants with violating the antifraud and registration provisions of the federal securities laws. In addition to the emergency relief granted by the Court, the SEC is seeking preliminary and permanent injunctions, disgorgement, prejudgment interest, civil penalties, and officer and-director bars against Link and Wood. The court has scheduled a hearing for Dec. 20, 2023 on the SEC’s motion for a preliminary injunction.

The SEC’s ongoing investigation is being conducted by enforcement staff in the SEC’s Fort Worth and Atlanta regional offices, including D. Thomas Keltner, Jonathan Scott, Carol Stumbaugh, and Cody Turley, under the supervision of Timothy McCole and B. David Fraser.

The SEC’s litigation will be led by Matthew Gulde and Tyson Lies. The Commission appreciates the assistance of the Arizona Corporation Commission, the North Dakota Securities Department, the Oklahoma Department of Securities, and the Texas State Securities Board.