On May 18, 2009, the U.S. Supreme Court granted certiorari in the Seventh Circuit’s decision affirming the conviction of media mogul Conrad Black and several other former Hollinger International executives for honest services fraud. Black v. United States, ___ U.S. ___, 77 U.S.L.W. 3632 (2009). The resulting decision could well clarify the elements and scope of 18 U.S.C. § 1346, which is used widely by federal prosecutors to gain convictions in public corruption or private business settings where the government may have difficulty proving that the victim was deprived of “money or property” as distinct from “the intangible right” of honest services. (See for instance the Winter 2009 edition of Day Pitney’s White Collar Quarterly, “Ninth Circuit Joins Other Circuits in Ruling that Honest Services Fraud Conviction of a Public Official Does Not Require a Violation of a State Law”).