What is the test for establishing a venue for an insider trading case in the SDNY?
MultiRegion, United States of America
The following excerpt is from United States v. Kirk Tang Yuk, 885 F.3d 57 (2nd Cir. 2018):
2 See United States v. Geibel , 369 F.3d 682, 697 (2d Cir. 2004) (finding mere fact that defendant misappropriated securities information in New York insufficient to establish venue in the SDNY in part because "to hold otherwise would be to in effect grant the Southern District of New York carte blanche on venue in virtually all insider trading cases" (internal quotation marks omitted) ).
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