The Case Western Reserve law review, “Insider-Trading Regulation after Salman v. United States,” focuses on whether or not a tipper can be convicted if their intentions were for personal benefit or for the purpose of exposing company's fraud. In the 1983 case, Dirks v.s SEC, the court based its decision to overturn the conviction on the fact that the tipper did not receive any personal benefit. The tipper’s motivations, in this case, were solely to expose the company’s fraud and it was argued that Dirks did not receive any commentary from disclosing the information. From this case comes the Dirks personal benefit test, which was used in the Salman vs United States case. In Salmon vs United States, Salmon was tipped information from extended
