In Salman, the Supreme Court adopted the Ninth Circuit's interpretation, finding that an insider-tipper receives a personal benefit where the tipper makes a gift of inside information to a trading relative or friend, and rejecting the additional requirements imposed by the Second Circuit in United States v. Newman. Critically, discuss Salman v. United States 1 580 U.S., 137 S. Ct. 420 (2016) as it relates to insider dealing in the USA. You are required to discuss the law before Salman, namely a review of the "Classical", The "Misappropriation" Theory and the "Deceptive Device" or "Affirmative Misrepresentation" Theory. Did Salman establish a new prescedent as it relate to insider dealing?

In Salman, the Supreme Court adopted the Ninth Circuit's interpretation, finding that an insider-tipper receives a personal benefit where the tipper makes a gift of inside information to a trading relative or friend, and rejecting the additional requirements imposed by the Second Circuit in United States v. Newman. Critically, discuss Salman v. United States 1 580 U.S., 137 S. Ct. 420 (2016) as it relates to insider dealing in the USA. You are required to discuss the law before Salman, namely a review of the "Classical", The "Misappropriation" Theory and the "Deceptive Device" or "Affirmative Misrepresentation" Theory. Did Salman establish a new prescedent as it relate to insider dealing?