1. Salman takes as a given the government's acknowledgement that Newman's knowledge test applied in that case, which was criminal. See generally Strader, (Re)conceptualizing Insider Trading: United States v. Newman and the Intent to Defraud, 80 Brook;L. Rev,2015
2. A finding of liability in Payton was subsequently affirmed;SEC v. Payton, 97 F. Supp.3d,0726
3. At roughly the same time as Judge Rakoff, another judge in the Southern District moved in the same direction by suggesting that the standard for tippee liability in civil cases should still be drawn from Obus;United States v. Goffer, 721 F.3d,2013
4. Insider Trading and Intangible Rights: The Redefinition of the Mail Fraud Statute, 26 Am;E G See;Crim. L. Rev,1988
5. Bill Wang gave this issue substantial coverage in his article Application of Mail and Wire Fraud Statutes to Criminal Liability for Stock Market Insider Trading and Tipping;U. Miami L. Rev,2015