The U.S. Court of Appeals for the Second Circuit shook the insider trading world in 2014 when it issued United States v. Newman, 773 F.3d 438 (2d Cir. 2014).  The court addressed the knowledge required for liability of remote tippees and what a personal benefit means in tipping cases.  I think the decision in that case remains important today, even after Salman v. United States, 137 S. Ct. 420 (2016).  Today we get into the knowledge discussion.