Conviction of man who got insider trading tip on country club napkin is affirmed. A jury convicted Robert H. Bray of insider trading after he got a tip about a bank on a country club napkin from a fellow member/bank executive and then used that nonpublic information to make a trading profit. The First Circuit affirmed, determining that the tip’s secretive manner was enough for the jury to decide that Bray knew that his tipper was giving him confidential information. Also, the district court’s error in instructing the jury that it could convict Bray if he “should have known” that the tipper had an obligation to keep the information confidential did not jeopardize the trial’s fairness. (2/24/2017) United States v. Robert H. Bray.