On January 19, the Supreme Court granted certiorari in Salman v. United States, to decide what the prosecution must prove to establish that a tipper received a “personal benefit.” In Salman, the Ninth Circuit held that a personal benefit is established when tips are made to a relative or friend as a gift. The Ninth Circuit’s decision disagreed with the Second Circuit’s decision in United States v. Newman, which interpreted “personal benefit” to require more than a friendship or familial relationship between the tipper and tippee. The Supreme Court previously declined to grant the Department of Justice’s petition for certiorari in Newman, but has decided to hear the issues in Salman, which squarely presents the question of what is required to establish “personal benefit.” More discussion of the Supreme Court decision can be found in our client alert here. Bassam Yacoub Salman v. United States, No. 15-628 (S. Ct. Jan. 19, 2016).