The following excerpt is from U.S. Sec. & Exch. Comm'n v. Conradt, 15-2887-cv, 15-2967-cv, 16-2694-cv (2nd Cir. 2017):
2. Conradt also argues that the district court's interpretation of Rule 60(b)(5)'s "based on" clause, and whether United States v. Newman, 773 F.3d 438 (2d Cir. 2014) changed our law for insider trading cases are subject to de novo review. Under either standard, we find no error.
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