KJS(SH:601579) Xin Lang Cai Jing·2026-02-13 13:29Core Viewpoint - The case represents the first administrative lawsuit in Shanghai regarding market manipulation, highlighting the regulatory boundaries of legitimate versus illegitimate market value management [3][13]. Summary of Violations - The main entities involved include Shanghai Dengcheng Consulting Management Co., Ltd., its president Liu Mouyu, and Jin Mouchun, the legal representative of Jinggong Group. The case revolves around a series of illegal transactions from December 2017 to April 2019 aimed at maintaining the stock price of "Huaijishan" and mitigating stock pledge risks [4][14]. - The manipulation process was divided into four stages: building positions, raising prices, maintaining prices, and liquidating positions. During the price-raising phase, the involved accounts ranked first in trading volume for 43 trading days, with over 40% of the buying volume in 20 trading days. The stock price of "Huaijishan" increased by 12.62%, significantly deviating from the Shanghai Composite Index's decline of 22.03% during the same period [5][15]. - The Shanghai Securities Regulatory Commission imposed fines totaling 2.4 million yuan on the involved parties, with 1.2 million yuan each for Jin Mouchun and Shanghai Dengcheng Consulting, and a 500,000 yuan fine for Liu Mouyu [6][16]. Administrative Litigation - Following the penalties, Shanghai Dengcheng Consulting and Liu Mouyu filed an administrative lawsuit against the Shanghai Securities Regulatory Commission, claiming their actions constituted legal market value management rather than market manipulation [6][16]. - The Shanghai Financial Court elevated the case, which became the first administrative lawsuit stemming from a market manipulation penalty, drawing significant attention from the capital market [7][16]. Court Ruling - The court ruled against Shanghai Dengcheng Consulting and Liu Mouyu, supporting the regulatory penalties. The court found their defenses lacked sufficient factual and legal support, noting that the timing of fund transfers and trading activities was highly correlated, and the involved funds violated basic investment diversification principles [8][17]. - The court emphasized that the so-called "legitimate market value management" was essentially a guise for market manipulation, and even if the manipulation resulted in losses, it did not absolve them of legal responsibility [8][18]. Core Controversy - The case clarifies the legal boundaries between "legitimate market value management" and "illegitimate market value management," dispelling two common misconceptions in the capital market: that market manipulation must result in profits to be prosecuted, and that one can evade liability by claiming market value management [9][18]. - The ruling sends a clear regulatory signal that the space for illegitimate market value management will continue to shrink, with enhanced regulatory scrutiny and tighter compliance requirements for the private equity industry [9][18].