I'm a little behind the curve on this one. For those of you who depend on me for your Second Circuit news, I'm sorry. On May 28, 2004, the Court in United State v. Geibel dismissed 80 counts of insider trading on the basis of venue. The only connection between the trades and New York is that the insider information was misappropriated in New York, which the Court found was insufficient to support venue. A few counts for which some evidence of a New York connection was submitted were upheld. A conspiracy count, which had New York connections was upheld (although the Court narrowed the conspiracy because the tipper had no knowledge of the ultimate tippees and vice versa), and the commercial bribery counts were upheld. The decision can be found here.