“A Wells Notice notifies the recipient that the SEC's Enforcement Division is close to recommending to the full Commission an action against the recipient and provides the recipient the opportunity to set forth his version of the law or facts.  The recipient's response, by which it sets forth its version of the law or facts, typically providing documents in support thereof, is termed a Wells Submission."


S.E.C. v. Internet Solutions for Business Inc., 509 F.3d 1161, 1163 & n.1 (9th Cir. 2007) (quotation marks and citation omitted).