What may the sec proceed about this situation


Problem 1: High Flyer Inc., a publicly held company, made an extraordinary corporate payout of a bonus to its CEO while it was under investigation by the SEC for fraud. Under SOX, what may the SEC proceed about this situation?

Problem 2: Please research one of the following cases:

Dirks v. SEC, 463 US 646 (1983);  Chiarella v. US, 445 US 222 (1980);  US v. Winans, 612 F Supp 827 (S.D.N.Y. 1985), NOT the Winans 1905 treaty case.

Problem 3: Who exactly are insiders who share a fiduciary duty under the insider trading rules?  We already researched Martha Stewart and Rajat Gupta.  What about Michael Miken, SAC Capital (Steven A Cohen) and the case of US v. O'Hagan, 521 US 642 (1997)?

Problem 4: Please research the case of SEC v. Texas Gulf Sulphur Co., 401 F 2d 833 (2nd Cir, NY, Aug 13, 1968).  What guidance does the case provide for us?

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