The Court earlier found that ING’s former subsidiary Successful Money Management Seminars, Inc. (“SMMS”), negligently licensed and promoted California financial advisors Gary Armitage, Jeffery Guidi, and their colleagues to provide seminar programs and related financial advice to employees at Fireman’s Fund’s Novato, California campus. On the advice of Armitage and his colleagues, the plaintiffs invested virtually all of their 401k plan accounts, pensions, and other money in what they believed to be safe investments, but which turned out to be risky, speculative private placements. Most of these investments subsequently failed, wiping out much and in some cases all of the plaintiffs’ retirement savings.