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Insider trading issues are again dominating the headlines. Insider trading violations occur when an individual in possession of material non-public information (a “tipper”) relays that information for personal gain (or in violation of a duty) to another person (a “tippee”), who trades on the basis of that information. One issue that frequently arises in such cases is whether an individual who receives such a tip has the requisite “scienter,” or state of mind, to have committed a violation.