Datasets:

codewithdark
/

SEC-RPT-Panel

 
 UNITED STATES OF AMERICA 
 before the 
 SECURITIES AND EXCHANGE COMMISSION 
SECURITIES EXCHANGE ACT OF 1934 
Release No. 66352 / February 7, 2012 
ACCOUNTING AND AUDITING ENFORCEMENT 
Release No.  3365 / February 7, 2012 
ADMINISTRATIVE PROCEEDING 
File No. 3-14753 
: 
: 
: 
In the Matter of : ORDER INSTITUTING ADMINISTRATIVE 
: PROCEEDINGS PURSUANT TO RULE 
 LYNNE NORMAN, : 102(e) OF THE COMMISSION’S RULES OF 
: PRACTICE, MAKING FINDINGS, AND 
Respondent. : IMPOSING REMEDIAL SANCTIONS 
: 
: 
____________________________________ : 
I. 
The Securities and Exchange Commission (“Commission”) deems it appropriate and in the 
public interest that public administrative proceedings be, and hereby are, instituted against Lynne 
Norman (“Respondent” or “Norman”) pursuant to Rule 102(e)(3)(i) of the Commission’s Rules of 
Practice.1 
II. 
In anticipation of the institution of these proceedings, Respondent has submitted an Offer 
of Settlement (the “Offer”) which the Commission has determined to accept.  Solely for the 
1 Rule 102(e)(3)(i) provides, in relevant part, that: 
The Commission, with due regard to the public interest and without preliminary hearing, may, by order, . . . 
suspend from appearing or practicing before it any . . . accountant . . . who has been by name . . . permanently 
enjoined by any court of competent jurisdiction, by reason of his or her misconduct in an action brought by the 
Commission, from violating or aiding and abetting the violation of any provision of the Federal securities laws or of 
the rules and regulations thereunder. 
 
purpose of these proceedings and any other proceedings brought by or on behalf of the 
Commission, or to which the Commission is a party, and without admitting or denying the findings 
herein, except as to the Commission’s jurisdiction over her and the subject matter of these 
proceedings, and the findings contained in Section III.3 below, which are admitted, Respondent 
consents to the entry of this Order Instituting Administrative Proceedings Pursuant to Rule 102(e) 
of the Commission’s Rules of Practice, Making Findings, and Imposing Remedial Sanctions 
(“Order”), as set forth below.   
III. 
On the basis of this Order and Respondent’s Offer, the Commission finds that: 
1. Symmetry Medical, Inc. (“Symmetry”), is a Delaware corporation 
headquartered in Warsaw, Indiana.  A manufacturer of medical implants and instruments as well 
as aerospace industry products, Symmetry’s subsidiaries include Symmetry Medical Sheffield 
LTD, f/k/a Thornton Precision Components, Limited (“TPC”).  Since 2003, TPC’s financial data 
has been consolidated into Symmetry’s financial statements filed with the Commission.  Since 
December 2004, Symmetry’s common stock has been registered with the Commission pursuant to 
Section 12(b) of the Exchange act and listed on the New York Stock Exchange.   
2. Norman, age 50 and a citizen of the United Kingdom, was employed as 
TPC’s controller from approximately 1989 to 2008.  Norman holds a B.A. in business studies from 
Sheffield University, but is not a UK Chartered Accountant and holds no other accounting licenses 
or certifications.  She was allowed to resign by Symmetry after disclosing her role in TPC’s 
accounting irregularities and assisting the company with its restatement of prior year financials.  
3. On February 1, 2012, a final judgment was entered by consent against 
Norman, permanently enjoining her from future violations of Sections 10(b) and 13(b)(5) of the 
Securities Exchange Act of 1934 (“Exchange Act”) and Rules 10b-5, 13b2-1 and 13b2-2 
thereunder, and from aiding and abetting violations of Sections 13(a), 13(b)(2)(A) and 13(b)(2)(B) 
of the Exchange Act and Rules 12b-20, 13a-1 and 13a-13, in the civil action styled, Securities and 
Exchange Commission v. Lynne Norman, et al. (“SEC v. Norman”) (Civil Action No. 3:12cv60), 
in the United States District Court for the Northern District of Indiana.   
4. The Commission’s complaint in SEC v. Norman alleged, among other 
things, that as the controller of TPC, Norman bore responsibility for ensuring the accuracy of 
TPC’s financial accounts on a monthly and quarterly basis and assisting TPC’s Finance Director 
in reporting TPC’s financial accounts to Symmetry for inclusion in Symmetry’s consolidated 
financial statements; that, between at least 2003 and September 2007, Norman knowingly 
participated in TPC’s manipulation of its financial accounts; that these manipulations included 
pre-booking sales revenues, booking fictitious sales revenues, engaging in sales-buyback 
arrangements, understating cost of revenues and creating fictitious work-in-process inventories, 
and overstating amounts for capitalized tool and die; that Norman knew (i) that the foregoing 
manipulations did not conform to US Generally Accepted Accounting Principles, (i) that the 
foregoing manipulations materially impacted TPC’s financial statements, (iii) that TPC’s 
2
 
financial statements were consolidated into Symmetry’s financial statements and (iv) that 
Symmetry was a US publicly traded company; that Norman made serial misrepresentations to 
Symmetry’s internal and external auditors concerning the foregoing manipulations; and that, 
notwithstanding all of the foregoing, Norman falsely attested in writing to the accuracy of TPC’s 
financial statements in 2007 after the departure of TPC’s Financial Director.   
IV. 
In view of the foregoing, the Commission deems it appropriate and in the public interest to 
impose the sanction agreed to in Respondent Norman’s Offer. 
Accordingly, it is hereby ORDERED, effective immediately, that Norman is suspended 
from appearing or practicing before the Commission as an accountant.
 By the Commission.
       E l i z a b e t h M . M u r p h y
       S e c r e t a r y 
3








































	UNITED STATES OF AMERICA
	before the
	SECURITIES AND EXCHANGE COMMISSION
	SECURITIES EXCHANGE ACT OF 1934
	Release No. 66352 / February 7, 2012
	ACCOUNTING AND AUDITING ENFORCEMENT
	Release No. 3365 / February 7, 2012
	ADMINISTRATIVE PROCEEDING
	File No. 3-14753
	:
	:
	:
	In the Matter of : ORDER INSTITUTING ADMINISTRATIVE
	: PROCEEDINGS PURSUANT TO RULE
	LYNNE NORMAN, : 102(e) OF THE COMMISSION’S RULES OF
	: PRACTICE, MAKING FINDINGS, AND
	Respondent. : IMPOSING REMEDIAL SANCTIONS
	:
	:
	____________________________________ :
	I.
	The Securities and Exchange Commission (“Commission”) deems it appropriate and in the
	public interest that public administrative proceedings be, and hereby are, instituted against Lynne
	Norman (“Respondent” or “Norman”) pursuant to Rule 102(e)(3)(i) of the Commission’s Rules of
	Practice.1
	II.
	In anticipation of the institution of these proceedings, Respondent has submitted an Offer
	of Settlement (the “Offer”) which the Commission has determined to accept. Solely for the
	1 Rule 102(e)(3)(i) provides, in relevant part, that:
	The Commission, with due regard to the public interest and without preliminary hearing, may, by order, . . .
	suspend from appearing or practicing before it any . . . accountant . . . who has been by name . . . permanently
	enjoined by any court of competent jurisdiction, by reason of his or her misconduct in an action brought by the
	Commission, from violating or aiding and abetting the violation of any provision of the Federal securities laws or of
	the rules and regulations thereunder.

















	purpose of these proceedings and any other proceedings brought by or on behalf of the
	Commission, or to which the Commission is a party, and without admitting or denying the findings
	herein, except as to the Commission’s jurisdiction over her and the subject matter of these
	proceedings, and the findings contained in Section III.3 below, which are admitted, Respondent
	consents to the entry of this Order Instituting Administrative Proceedings Pursuant to Rule 102(e)
	of the Commission’s Rules of Practice, Making Findings, and Imposing Remedial Sanctions
	(“Order”), as set forth below.
	III.
	On the basis of this Order and Respondent’s Offer, the Commission finds that:
	1. Symmetry Medical, Inc. (“Symmetry”), is a Delaware corporation
	headquartered in Warsaw, Indiana. A manufacturer of medical implants and instruments as well
	as aerospace industry products, Symmetry’s subsidiaries include Symmetry Medical Sheffield
	LTD, f/k/a Thornton Precision Components, Limited (“TPC”). Since 2003, TPC’s financial data
	has been consolidated into Symmetry’s financial statements filed with the Commission. Since
	December 2004, Symmetry’s common stock has been registered with the Commission pursuant to
	Section 12(b) of the Exchange act and listed on the New York Stock Exchange.
	2. Norman, age 50 and a citizen of the United Kingdom, was employed as
	TPC’s controller from approximately 1989 to 2008. Norman holds a B.A. in business studies from
	Sheffield University, but is not a UK Chartered Accountant and holds no other accounting licenses
	or certifications. She was allowed to resign by Symmetry after disclosing her role in TPC’s
	accounting irregularities and assisting the company with its restatement of prior year financials.
	3. On February 1, 2012, a final judgment was entered by consent against
	Norman, permanently enjoining her from future violations of Sections 10(b) and 13(b)(5) of the
	Securities Exchange Act of 1934 (“Exchange Act”) and Rules 10b-5, 13b2-1 and 13b2-2
	thereunder, and from aiding and abetting violations of Sections 13(a), 13(b)(2)(A) and 13(b)(2)(B)
	of the Exchange Act and Rules 12b-20, 13a-1 and 13a-13, in the civil action styled, Securities and
	Exchange Commission v. Lynne Norman, et al. (“SEC v. Norman”) (Civil Action No. 3:12cv60),
	in the United States District Court for the Northern District of Indiana.
	4. The Commission’s complaint in SEC v. Norman alleged, among other
	things, that as the controller of TPC, Norman bore responsibility for ensuring the accuracy of
	TPC’s financial accounts on a monthly and quarterly basis and assisting TPC’s Finance Director
	in reporting TPC’s financial accounts to Symmetry for inclusion in Symmetry’s consolidated
	financial statements; that, between at least 2003 and September 2007, Norman knowingly
	participated in TPC’s manipulation of its financial accounts; that these manipulations included
	pre-booking sales revenues, booking fictitious sales revenues, engaging in sales-buyback
	arrangements, understating cost of revenues and creating fictitious work-in-process inventories,
	and overstating amounts for capitalized tool and die; that Norman knew (i) that the foregoing
	manipulations did not conform to US Generally Accepted Accounting Principles, (i) that the
	foregoing manipulations materially impacted TPC’s financial statements, (iii) that TPC’s
	2

















	financial statements were consolidated into Symmetry’s financial statements and (iv) that
	Symmetry was a US publicly traded company; that Norman made serial misrepresentations to
	Symmetry’s internal and external auditors concerning the foregoing manipulations; and that,
	notwithstanding all of the foregoing, Norman falsely attested in writing to the accuracy of TPC’s
	financial statements in 2007 after the departure of TPC’s Financial Director.
	IV.
	In view of the foregoing, the Commission deems it appropriate and in the public interest to
	impose the sanction agreed to in Respondent Norman’s Offer.
	Accordingly, it is hereby ORDERED, effective immediately, that Norman is suspended
	from appearing or practicing before the Commission as an accountant.
	By the Commission.
	E l i z a b e t h M . M u r p h y
	S e c r e t a r y
	3