Under 15 USC 78u(d)(5), in an action commenced by the SEC, the court may award “any equitable relief that may be appropriate or necessary for the benefit of investors.” The term “equitable relief” allows the court to grant the categories of relief typically available in equity as shown by consulting works on equity jurisprudence. Those works show that restitution or disgorgement of a defendant’s profits earned by its wrongdoing is a typical form of equitable remedy which, therefore, a court may award in an action brought by the SEC. However, to fit within the bounds of traditional equity practice, the restitution/disgorgement must (a) benefit victims of the wrongdoing, not the government, (b) limit restitution/disgorgement to those defendants that actually received the victims’ money or obtained income from the wrongdoing, absolving co-defendants unless they were partners in the wrongdoing or co-conspirrators, and (c) limit restitution/disgorgement to net profits, after deduction of “legitimate” expenses that are not merely wrongful gains under a different name.