By David Miller and Grant MacQueen ( June 27, 2018, 1:03 PM EDT) -- On June 25, 2018, the U.S. Court of Appeals for the Second Circuit revisited its August 2017 insider trading decision in United States v. Martoma,[1] amending its earlier landmark opinion to avoid a panel conflict with the Second Circuit's 2014 decision in United States v. Newman.[2] In its amended opinion, the court again tackles an unanswered question left in Newman's wake: What are the contours of a tipper's required "personal benefit" in a gift-giving context? In Martoma II, the court walks back its personal-benefit definition and rejection of Newman, but, as shown below, may achieve the same practical result as Martoma I. Martoma II is the latest in a string of critical insider trading decisions and may have significant ramifications for the government's enforcement efforts....