On June 20th, the Second Circuit held that plaintiffs' "hot news" misappropriation claim is preempted by federal copyright law. Plaintiffs, stock analysts who provided selected clients with trading recommendations, alleged that defendant violated their copyrighted research reports by collecting and disseminating plaintiffs' summary recommendations. Rejecting the plaintiff's claim, the court held that the defendant is reporting the underlying news that plaintiffs are making certain stock trading recommendations. Barclays Capital Inc. v. Theflyonthewall.com, Inc.