The Securities and Exchange Commission filed civil charges against Salvador Chavarria, John Nieto and Glenn Leftwich in federal court in western Texas. Chavarria and Nieto settled the charges. The case is pending against Leftwich. Their attorneys couldn't immediately be identified for comment.

Bob Pearson, a Dell spokesman, said that Dell was "contacted by the SEC well past a year ago, and we immediately agreed to cooperate." He said that the company does not comment on current or former employees. It wasn't clear whether the men still work at Dell. A person who answered the phone at Nieto's home number said he still worked at the Round Rock, Texas, company.

The SEC has been cracking down on insider trading by individuals, charging more than 50 people in its current fiscal year with buying or selling securities based on their access to confidential information. The 2007 fiscal year ends on Sept. 30.

The SEC said that the three men had traded before Dell's Aug. 11, 2005, announcement that quarterly revenue had fallen short of analyst expectations. The SEC said that Leftwich in addition made trades before Dell announced on Oct. 31, 2005, that it wouldn't hit quarterly earnings targets. The men allegedly used put options, which amount to bets that stock prices will fall.

Under the settlement, Chavarria will pay almost $325,000, including the return of $153,240 in profits. Nieto will pay about $35,000, including the return of $16,677 in improperly earned profits. The men weren't barred from working as accountants at publicly traded companies under the settlement.