Details of the fraud allegedly conceived by Garth Drabinsky and Myron Gottlieb were eventually revealed to the public by the SEC, the Ontario Securities Commission-a Canadian agency comparable to the SEC – and publicy available records of various court proceedings in civil lawsuits. In numerous enforcement and litigation releases, SEC officials repeatedly used the descriptive phrase “pervasive and multi-faceted” when referring to the Livent fraud. One of the earliest elements of the fraud was a large kickback scheme