Financial Services special counsel Gary DeWaal was quoted by Hedge Fund Legal and Compliance Digest on a landmark federal appeals court decision resulting from the Martoma insider trading case. Gary noted the appeal speaks to what constitutes personal benefit. He stated, "The underlying question in this instance is: 'What constitutes a personal benefit where there isn't a family relationship or a meaningful, close and personal relationship between the tipper and tippee?'" He added, "The court ultimately said in this case there had been a quid pro quo as there had been prior payments so the tipper could reasonably believe his disclosures were related to the compensation he previously received." ("US Court Upholds SAC Capital PM's Insider Trading Conviction," July 3, 2018)