Contrary to some reports that I have seen, I believe these cases do not represent some inherent hostility by the Commission toward expert networks, nor do they indicate that the Commission is seeking to undermine the mosaic theory, under which analysts and investors are free to develop market insights through assembly of information from different public and private sources, so long as that information is not material nonpublic information obtained in breach of or by virtue of a duty or relationship of trust and confidence.

Carlo V. di Florio, Director, Office of Compliance Inspections and Examinations, U.S. Securities and Exchange Commission, remarking on the misplaced focus on expert networks during the unfolding of the various insider trading scandals that “seem to have spawned some urban legends and misunderstandings”: via speech at the Omni Shoreham Hotel, Washington, D.C., March 21, 2011

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