The Second Circuit recently decided a pair of insider trading cases that provide additional guidance on the law following the court’s 2017 decision in Martoma. In United States v. Klein, 2019 U.S. App. LEXIS 858 (2d Cir. Jan. 10, 2019), the Second Circuit upheld Defendant Schulman’s insider trading conviction. Schulman, the “tipper,” did not directly trade on material, non-public information, but rather shared it with Klein,… More