Factual findings did not support a district court’s conclusion that a former analyst for two financial services companies intended to cause a loss of $12 million when he unlawfully copied proprietary computer files and used the data to conduct computerized stock market trades for himself. A 36-month prison sentence based on the erroneous intended loss calculation was vacated by the U.S. Court of Appeals in Chicago. The appellate court also held that the district court erred in ordering the analyst to pay over $750,000 in restitution without requiring the government to provide a complete accounting of the amount spent by victims in their investigation of the trade secrets theft (United States v. Pu, February 24, 2016, Williams, A.).

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