Mr. Menezes had access to better information than the public did about Argentina. He knew the company was going to miss analysts' earnings expectations.

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This case is a reminder that cashless exercise transactions are no different from other stock sales from a legal standpoint. Executives are under a duty not to trade when they have material information that the market does not.

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This case is an example of our ongoing effort to stamp out fraud and abuses by investors in the PIPEs market, and it will continue.

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