[SCHEDULE 13D/A] ProQR Therapeutics N.V. SEC Filing

Rhea-AI Filing Summary

Van Herk group disclosed ownership of 14,329,690 ordinary shares of ProQR Therapeutics N.V. (PRQR), representing 13.6% of the company based on 105,344,052 shares outstanding as of June 30, 2025. The filing (Amendment No. 3 to a Schedule 13D) reports that Van Herk Investments B.V. purchased 1,055,000 ordinary shares in open-market transactions from September 5, 2025 to September 29, 2025 for an aggregate net amount of $2,300,635.14 using its general working capital. The reporting group is a network of Netherlands entities and related parties coordinated through Adrianus van Herk, and they state the shares were acquired for investment purposes in the ordinary course of business and that they may review or change their position over time, including engaging with management, acquiring or selling shares, or pursuing other strategic actions.

Positive

• Material stake disclosed: Beneficial ownership of 14,329,690 shares, representing 13.6% of outstanding shares, a clearly material position.
• Transparent funding disclosure: Purchases of 1,055,000 shares for an aggregate net amount of $2,300,635.14 funded from VHI's general working capital.

Negative

• Potential for strategic actions: The Reporting Persons reserve broad rights to engage with management or pursue transactions, which could create uncertainty for other shareholders.
• Concentrated ownership: A 13.6% block held by a coordinated group may influence governance or strategic outcomes without further disclosure of intentions.

Insights

Financial Analyst

TL;DR: Van Herk's 13.6% stake is sizable and material; recent open-market purchases added 1.06M shares for $2.30M.

From a shareholder-impact perspective, a disclosed 13.6% beneficial ownership in a small-to-mid cap biotech is material and may attract market attention. The filing confirms active accumulation through open-market trades and that funding came from VHI's working capital. The group frames the holding as investment-oriented but explicitly reserves the right to engage with management or pursue strategic transactions, which introduces potential governance or strategic implications for ProQR. No litigation disclosures or additional transactions in the prior 60 days beyond the reported purchases are noted.

Corporate Governance Expert

TL;DR: A coordinated Netherlands-based ownership structure controls 13.6% and signals potential for engagement but not an immediate activist campaign.

The reporting entities form a layered ownership and control structure culminating with Adrianus van Herk holding depositary receipts and key management roles. The Schedule 13D language is broad, preserving options to communicate with the board or propose changes, which is standard for investors taking a material stake. The disclosure of source of funds and absence of legal proceedings reduces near-term governance risk; however, the size of the stake makes any future engagement credible to other shareholders and the board.

SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

SCHEDULE 13D

Under the Securities Exchange Act of 1934

(Amendment No. 3)

ProQR Therapeutics N.V.

(Name of Issuer)

Ordinary Shares, nominal value Euro 0.04 per share

(Title of Class of Securities)

N71542109

(CUSIP Number)

Van Herk Investments B.V.
Lichtenauerlaan 30,,
The Netherlands, P7, 3062 ME
31-10-241-1555

Evan S. Simpson
1 New Fetter Lane,,
London, X0, EC4A 1AN
44 20 795984-26

(Name, Address and Telephone Number of Person Authorized to Receive Notices and Communications)

09/29/2025

(Date of Event Which Requires Filing of This Statement)

If the filing person has previously filed a statement on Schedule 13G to report the acquisition that is the subject of this Schedule 13D, and is filing this schedule because of §§ 240.13d-1(e), 240.13d-1(f) or 240.13d-1(g), check the following box.

The information required on the remainder of this cover page shall not be deemed to be "filed" for the purpose of Section 18 of the Securities Exchange Act of 1934 ("Act") or otherwise subject to the liabilities of that section of the Act but shall be subject to all other provisions of the Act (however, see the Notes).

SCHEDULE 13D

CUSIP No. N71542109

1

Name of reporting person

Van Herk Investments B.V.

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

BK, WC, PF

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

NETHERLANDS

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 14,329,690.00
8	Shared Voting Power 0.00
9	Sole Dispositive Power 14,329,690.00
10	Shared Dispositive Power 0.00

11

Aggregate amount beneficially owned by each reporting person

14,329,690.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

13.6 %

14

Type of Reporting Person (See Instructions)

CO

Comment for Type of Reporting Person:

* Based on 105,344,052 ordinary shares, nominal value Euro 0.04 per share, of ProQR Therapeutics N.V. (the "Issuer") issued and outstanding as of June 30, 2025, as reported in the Issuer's Form 6-K filed with the SEC on August 7, 2025.

SCHEDULE 13D

CUSIP No. N71542109

1

Name of reporting person

Van Herk Investments THI B.V.

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

BK, WC, PF

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

NETHERLANDS

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 0.00
8	Shared Voting Power 14,329,690.00
9	Sole Dispositive Power 0.00
10	Shared Dispositive Power 14,329,690.00

11

Aggregate amount beneficially owned by each reporting person

14,329,690.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

13.6 %

14

Type of Reporting Person (See Instructions)

CO

Comment for Type of Reporting Person:

* Based on 105,344,052 ordinary shares, nominal value Euro 0.04 per share, of the Issuer issued and outstanding as of June 30, 2025, as reported in the Issuer's Form 6-K filed with the SEC on August 7, 2025.

SCHEDULE 13D

CUSIP No. N71542109

1

Name of reporting person

Van Herk Private Equity Investments B.V.

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

BK, WC, PF

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

NETHERLANDS

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 0.00
8	Shared Voting Power 14,329,690.00
9	Sole Dispositive Power 0.00
10	Shared Dispositive Power 14,329,690.00

11

Aggregate amount beneficially owned by each reporting person

14,329,690.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

13.6 %

14

Type of Reporting Person (See Instructions)

CO

Comment for Type of Reporting Person:

* Based on 105,344,052 ordinary shares, nominal value Euro 0.04 per share, of the Issuer issued and outstanding as of June 30, 2025, as reported in the Issuer's Form 6-K filed with the SEC on August 7, 2025.

SCHEDULE 13D

CUSIP No. N71542109

1

Name of reporting person

Stichting Administratiekantoor Penulata

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

BK, WC, PF

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

NETHERLANDS

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 0.00
8	Shared Voting Power 14,329,690.00
9	Sole Dispositive Power 0.00
10	Shared Dispositive Power 14,329,690.00

11

Aggregate amount beneficially owned by each reporting person

14,329,690.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

13.6 %

14

Type of Reporting Person (See Instructions)

OO

Comment for Type of Reporting Person:

* Based on 105,344,052 ordinary shares, nominal value Euro 0.04 per share, of the Issuer issued and outstanding as of June 30, 2025, as reported in the Issuer's Form 6-K filed with the SEC on August 7, 2025.

SCHEDULE 13D

CUSIP No. N71542109

1

Name of reporting person

Van Herk Management Services B.V.

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

BK, WC, PF

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

NETHERLANDS

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 0.00
8	Shared Voting Power 14,329,690.00
9	Sole Dispositive Power 0.00
10	Shared Dispositive Power 14,329,690.00

11

Aggregate amount beneficially owned by each reporting person

14,329,690.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

13.6 %

14

Type of Reporting Person (See Instructions)

CO

Comment for Type of Reporting Person:

* Based on 105,344,052 ordinary shares, nominal value Euro 0.04 per share, of the Issuer issued and outstanding as of June 30, 2025, as reported in the Issuer's Form 6-K filed with the SEC on August 7, 2025.

SCHEDULE 13D

CUSIP No. N71542109

1

Name of reporting person

Onroerend Goed Beheer- en Beleggingsmaatschappij A. van Herk B.V.

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

BK, WC, PF

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

NETHERLANDS

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 0.00
8	Shared Voting Power 14,329,690.00
9	Sole Dispositive Power 0.00
10	Shared Dispositive Power 14,329,690.00

11

Aggregate amount beneficially owned by each reporting person

14,329,690.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

13.6 %

14

Type of Reporting Person (See Instructions)

CO

Comment for Type of Reporting Person:

* Based on 105,344,052 ordinary shares, nominal value Euro 0.04 per share, of the Issuer issued and outstanding as of June 30, 2025, as reported in the Issuer's Form 6-K filed with the SEC on August 7, 2025.

SCHEDULE 13D

CUSIP No. N71542109

1

Name of reporting person

A. van Herk Holding B.V.

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

BK, WC, PF

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

NETHERLANDS

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 0.00
8	Shared Voting Power 14,329,690.00
9	Sole Dispositive Power 0.00
10	Shared Dispositive Power 14,329,690.00

11

Aggregate amount beneficially owned by each reporting person

14,329,690.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

13.6 %

14

Type of Reporting Person (See Instructions)

CO

Comment for Type of Reporting Person:

* Based on 105,344,052 ordinary shares, nominal value Euro 0.04 per share, of the Issuer issued and outstanding as of June 30, 2025, as reported in the Issuer's Form 6-K filed with the SEC on August 7, 2025.

SCHEDULE 13D

CUSIP No. N71542109

1

Name of reporting person

Stichting Administratiekantoor Abchrys

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

BK, WC, PF

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

NETHERLANDS

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 0.00
8	Shared Voting Power 14,329,690.00
9	Sole Dispositive Power 0.00
10	Shared Dispositive Power 14,329,690.00

11

Aggregate amount beneficially owned by each reporting person

14,329,690.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

13.6 %

14

Type of Reporting Person (See Instructions)

OO

Comment for Type of Reporting Person:

* Based on 105,344,052 ordinary shares, nominal value Euro 0.04 per share, of the Issuer issued and outstanding as of June 30, 2025, as reported in the Issuer's Form 6-K filed with the SEC on August 7, 2025.

SCHEDULE 13D

CUSIP No. N71542109

1

Name of reporting person

Adrianus van Herk

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

BK, WC, PF

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

NETHERLANDS

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 0.00
8	Shared Voting Power 14,329,690.00
9	Sole Dispositive Power 0.00
10	Shared Dispositive Power 14,329,690.00

11

Aggregate amount beneficially owned by each reporting person

14,329,690.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

13.6 %

14

Type of Reporting Person (See Instructions)

IN

Comment for Type of Reporting Person:

* Based on 105,344,052 ordinary shares, nominal value Euro 0.04 per share, of the Issuer issued and outstanding as of June 30, 2025, as reported in the Issuer's Form 6-K filed with the SEC on August 7, 2025.

SCHEDULE 13D

Item 1.	Security and Issuer
(a)	Title of Class of Securities: Ordinary Shares, nominal value Euro 0.04 per share
(b)	Name of Issuer: ProQR Therapeutics N.V.
(c)	Address of Issuer's Principal Executive Offices: Zernikedreef 9, Leiden, NETHERLANDS , 2333 CK.
Item 1 Comment: This Schedule 13D/A (this "Amendment No. 3") amends the Schedule 13D filed on May 28, 2025, as amended by Amendment No. 1 filed on August 20, 2025 and Amendment No. 2 filed on September 4, 2025 (collectively, the "Original Schedule 13D," and as amended and supplemented by this Amendment No. 3, the "Schedule 13D"). Except as amended hereby, the original disclosure set forth in the Original Schedule 13D shall remain unchanged. All capitalized terms used and not expressly defined herein have the respective meanings ascribed to such terms in the Original Schedule 13D.
Item 2.	Identity and Background
(a)	The information previously provided in response to Item 2 is hereby amended and restated by replacing the text thereof in its entirety with the following: This statement is being filed by (i) Van Herk Investments B.V., a private company with limited liability incorporated under the laws of the Netherlands ("VHI"), with respect to Ordinary Shares, nominal value Euro 0.04 per share (the "Ordinary Shares"), beneficially owned by it, (ii) Van Herk Investments THI B.V., a private company with limited liability incorporated under the laws of the Netherlands ("VHIT"), with respect to Ordinary Shares beneficially owned by VHI, (iii) Van Herk Private Equity Investments B.V., a private company with limited liability incorporated under the laws of the Netherlands ("VHPI"), with respect to Ordinary Shares beneficially owned by VHI and VHIT, (iv) Stichting Administratiekantoor Penulata, a foundation organized under the laws of the Netherlands ("Penulata"), with respect to Ordinary Shares beneficially owned by VHI, VHIT and VHPI, (v) Van Herk Management Services B.V., a private company with limited liability incorporated under the laws of the Netherlands ("VHMS"), with respect to Ordinary Shares beneficially owned by VHI, VHIT and VHPI, (vi) Onroerend Goed Beheer- en Beleggingsmaatschappij A. van Herk B.V., a private company with limited liability incorporated under the laws of the Netherlands ("OGBBA"), with respect to Ordinary Shares beneficially owned by VHI, VHIT, VHPI and VHMS, (vii) A. van Herk Holding B.V., a private company with limited liability incorporated under the laws of the Netherlands ("Holdings"), with respect to Ordinary Shares beneficially owned by VHI, VHIT, VHPI, VHMS and OGBBA, (viii) Stichting Administratiekantoor Abchrys, a foundation organized under the laws of the Netherlands ("Abchrys"), with respect to Ordinary Shares beneficially owned by VHI, VHIT, VHPI, VHMS, OGBBA and Holdings, and (ix) Adrianus van Herk ("Mr. van Herk") with respect to Ordinary Shares beneficially owned by VHI, VHIT, VHPI, VHMS, OGBBA, Holdings, Penulata and Abchrys. Each of Mr. van Herk, VHIT, VHPI, Penulata, VHMS, OGBBA, Holdings and Abchrys disclaims beneficial ownership of the securities covered by this statement.
(b)	The principal business address of each of Mr. van Herk, VHI, VHIT, VHPI, Penulata, VHMS, OGBBA, Holdings and Abchrys is: Lichtenauerlaan 30 3062 ME Rotterdam The Netherlands
(c)	Mr. van Herk is (i) an investor, (ii) the holder of all of the depositary receipts issued by Penulata and Abchrys, (iii) the sole board member of Penulata and Abchrys, and (iv) the sole managing director of VHMS, OGBBA and Holdings. Penulata holds substantially all of the issued and outstanding shares of VHPI. VHPI is the sole shareholder of VHIT. VHIT is the sole shareholder of VHI. VHI is principally engaged in making investments. Abchrys holds substantially all of the issued and outstanding shares of Holdings. Holdings is the sole shareholder of OGBBA. OGBBA is the sole shareholder of VHMS and is principally engaged in making investments. VHMS is the sole managing director of VHI, VHIT and VHPI.
(d)	During the last five years, none of the Reporting Persons, nor, to the knowledge of the Reporting Persons, none of the executive officers or directors of the Reporting Persons, if applicable, has been convicted in a criminal proceeding (excluding traffic violations or similar misdemeanors).
(e)	During the last five years, none of the Reporting Persons, nor, to the knowledge of the Reporting Persons, none of the executive officers or directors of the Reporting Persons, if applicable, has been a party to a civil proceeding of a judicial or administrative body of a competent jurisdiction and as a result of such proceeding was or is subject to a judgment, decree or final order enjoining future violations of, or prohibiting or mandating activities subject to, federal or state securities laws or finding any violation with respect to such laws.
(f)	Each of VHI, VHIT, VHPI, VHMS, OGBBA and Holdings is a private company with limited liability incorporated under the laws of the Netherlands. Penulata and Abchrys are Netherlands foundations. Mr. van Herk is a citizen of the Netherlands.
Item 3.	Source and Amount of Funds or Other Consideration
	Item 3 of the Schedule 13D is amended by adding the following: From September 5, 2025 to September 29, 2025, VHI effected open market transactions in Ordinary Shares for its own account and ultimately acquired an aggregate of 1,055,000 Ordinary Shares for an aggregate net amount of $2,300,635.14. The sources of the funding for the purchase of Ordinary Shares were the general working capital of VHI.
Item 4.	Purpose of Transaction
	Item 4 of the Schedule 13D is amended by adding the following: The Reporting Persons acquired the Ordinary Shares reported herein for investment purposes in the ordinary course of business. The Reporting Persons intend to review their investment in the Issuer on a continuing basis. Depending on various factors including, without limitation, the Issuer's financial position and investment strategy, the price levels of the Ordinary Shares, conditions in the securities markets and general economic and industry conditions, the Reporting Persons may in the future take such actions with respect to their investment in the Issuer as they deem appropriate including, without limitation, engaging in communications with management and the board of directors of the Issuer, engaging in discussions with stockholders of the Issuer or other third parties about the Issuer and the Reporting Persons' investment, including potential business combinations or dispositions involving the Issuer or certain of its businesses, making recommendations or proposals to the Issuer concerning changes to the capitalization, ownership structure, board structure (including board composition), potential business combinations or dispositions involving the Issuer or certain of its businesses, or suggestions for improving the Issuer's financial and/or operational performance, purchasing additional Ordinary Shares, selling some or all of their Ordinary Shares, engaging in short selling of or any hedging or similar transaction with respect to the Ordinary Shares, including swaps and other derivative instruments, or changing their intention with respect to any and all matters referred to in Item 4.
Item 5.	Interest in Securities of the Issuer
(a)	The information previously provided in response to Item 5 is hereby amended and restated by replacing the text thereof in its entirety with the following: The information set forth in or incorporated by reference in Items 2, 3, 4 and 6 and on the cover pages of this Schedule 13D is incorporated by reference in its entirety into this Item 5.
(b)	The information set forth in or incorporated by reference in Items 2, 3, 4 and 6 and on the cover pages of this Schedule 13D is incorporated by reference in its entirety into this Item 5.
(c)	Except as set forth in this Schedule 13D, no transactions in Ordinary Shares of the Issuer have been effected during the past sixty days by any of the Reporting Persons.
(d)	Except as set forth herein, to the knowledge of the Reporting Persons, no other person has the right to receive or the power to direct the receipt of dividends from, or the proceeds from the sale of, any securities of the Issuer beneficially owned by the Reporting Persons as described in this Item 5.
(e)	Not applicable.
Item 7.	Material to be Filed as Exhibits.
	None.

SIGNATURE

After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete and correct.

Van Herk Investments B.V.

Signature:	/s/ Erik G.A. Esveld
Name/Title:	Erik G.A. Esveld/Attorney-In-Fact*
Date:	09/30/2025

Van Herk Investments THI B.V.

Signature:	/s/ Erik G.A. Esveld
Name/Title:	Erik G.A. Esveld/Attorney-In-Fact*
Date:	09/30/2025

Van Herk Private Equity Investments B.V.

Signature:	/s/ Erik G.A. Esveld
Name/Title:	Erik G.A. Esveld/Attorney-In-Fact*
Date:	09/30/2025

Stichting Administratiekantoor Penulata

Signature:	/s/ Erik G.A. Esveld
Name/Title:	Erik G.A. Esveld/Attorney-In-Fact*
Date:	09/30/2025

Van Herk Management Services B.V.

Signature:	/s/ Erik G.A. Esveld
Name/Title:	Erik G.A. Esveld/Attorney-In-Fact*
Date:	09/30/2025

Onroerend Goed Beheer- en Beleggingsmaatschappij A. van Herk B.V.

Signature:	/s/ Erik G.A. Esveld
Name/Title:	Erik G.A. Esveld/Attorney-In-Fact*
Date:	09/30/2025

A. van Herk Holding B.V.

Signature:	/s/ Erik G.A. Esveld
Name/Title:	Erik G.A. Esveld/Attorney-In-Fact*
Date:	09/30/2025

Stichting Administratiekantoor Abchrys

Signature:	/s/ Erik G.A. Esveld
Name/Title:	Erik G.A. Esveld/Attorney-In-Fact*
Date:	09/30/2025

Adrianus van Herk

Signature:	/s/ Erik G.A. Esveld
Name/Title:	Erik G.A. Esveld/Attorney-In-Fact*
Date:	09/30/2025

Comments accompanying signature:

* Pursuant to a Power of Attorney, dated as of September 16, 2019, by and among the Reporting Persons.

FAQ

What percentage of ProQR (PRQR) does Van Herk now own?

The Van Herk reporting group beneficially owns 14,329,690 ordinary shares, equal to 13.6% of ProQR based on 105,344,052 shares outstanding as of June 30, 2025.

How many shares did Van Herk recently acquire and for how much?

Van Herk Investments B.V. acquired 1,055,000 ordinary shares in open-market transactions from September 5 to September 29, 2025 for an aggregate net amount of $2,300,635.14.

What was the source of funds for the share purchases?

The filing states the purchases were funded from the general working capital of Van Herk Investments B.V.

Did the filing state any intent to change ProQR's board or operations?

The Reporting Persons said the shares were acquired for investment purposes but reserved the right to review their investment and potentially engage with management, propose changes to board composition or pursue strategic transactions.

Are there any legal proceedings disclosed against the Reporting Persons?

No. The filing states that during the last five years none of the Reporting Persons has been convicted in a criminal proceeding or been subject to specified civil enforcement orders.