Maher was a Citigroup investment banker with extensive access to sensitive client information. Maher’s brother, Michael, kept pestering him for information he could use to trade while the public was unaware. Maher provided such information. Unknown to him, Michael was also passing the information to Salman, Michael’s friend and Maher’s brother-in-law, who reaped profits of $1.5 million. Salman knew the information came from Maher. He was convicted of insider trading and sentenced to 36 months in prison and $730,000 in restitution. On appeal to the Ninth Circuit, Salman asserted that he could not be found guilty of insider trading because Maher had received no personal benefit in the form of “a pecuniary or similarly valuable nature,” as was held necessary by the Second Circuit, interpreting Dirks v. SEC, 463 U.S. 646 (1983), in United States v. Newman, 773 F.3d 438 (2014), a decision rendered while the Ninth Circuit case was pending. 

Question 

Identify a range of circumstances in which a tipper would be viewed as having received sufficient personal benefit to make the tippee liable for insider trading.