In a 8-1 ruling, the Supreme Court placed limits on the amount the SEC can seek in disgorgement from offenders by excluding the reasonable expenses the investors would have incurred in the investment. The SEC can now only seek disgorgement of net profits and said the disgorgement must go to investors who suffered harm.
A few good post on it: Reuters Article - U.S. Supreme Court sets limits on SEC's power to recover ill-gotten gains
National Law Review Article - Supreme Court Upholds SEC Penalty, but Tasks Ninth Circuit with Defining Wrongful “Profits”
Supreme Court Ruling - LIU ET AL. v. SECURITIES AND EXCHANGE COMMISSION