As a condition of settling civil charges, the Securities and Exchange Commission (“SEC”) normally permits those it sues to say in a consent order that they neither admit nor deny the SEC’s allegations. But that’s not as big a break for some litigants as it seems, because the SEC also has a rule that bars those litigants from making any public statement, even an indirect one, which takes issue with the validity of the SEC’s charges.1 In other words, the SEC does not require y