"As Ripple's opposition explained, in comparable (and even in more egregious) cases, the SEC has agreed to civil penalties ranging from 0.6% to 1.8% of the defendant's gross revenues," said lawyers for Ripple. "Terraform fits that pattern. Here, by contrast, the SEC seeks a civil penalty far exceeding that range, even though there are no allegations of fraud in this case and Institutional Buyers did not suffer substantial losses. Terraform thus confirms that the Court should reject the SEC's disproportionate and unprecedented request and that an appropriate civil penalty would be no more than $10 million."