The following excerpt is from United States v. Litvak, 808 F.3d 160 (2nd Cir. 2015):
Id. at 93.23 Vilar's holding is consistent with our earlier observation that "the Government's burden with respect to criminal intent on [ ] Securities Exchange Act counts [is] less than under [ ] mail fraud counts," United States v. Dixon, 536 F.2d 1388, 1398 (2d Cir.1976), and forecloses Litvak's argument here.24
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