The Feinblatt et al. matter was an insider-trading enforcement action brought by the U.S. Securities and Exchange Commission (concerning the alleged tipping of material nonpublic information about Polycom, Inc. (“Polycom”). The Commission alleged that Sunil Bhalla, Senior Vice President and General Manager of Polycom’s Voice Division and a member of the company’s Executive Committee, conveyed material nonpublic information about Polycom’s financial performance to individual investor Roomy Khan, who traded Polycom call options in advance of the company’s earnings announcements.
The Commission retained Mark E. Zmijewski —Professor Emeritus at The University of Chicago Booth School of Business— to review and respond to the rebuttal report submitted by the defense’s expert. Professor Zmijewski was asked to evaluate whether the analyses in the defendant’s expert report supported the conclusion of insider trading and to assess whether the tips conveyed material nonpublic information.
Professor Zmijewski identified and analyzed methodological issues in the defendant expert’s analysis and assessed the statistical significance of the tips.