District Court Judge Jed S. Rakoff of the Southern District of New York imposed a two-year sentence on Rajat Gupta for his insider-trading conviction. In his Sentencing Memorandum and Order, Judge Rakoff criticized the U.S. Sentencing Guidelines' ability to dictate an appropriate sentence. He wrote, "[t]he notion that this complicated [sentencing] analysis, and moral responsibility, can be reduced to the mechanical adding-up of a small set of numbers artificially assigned to a few arbitrarily-selected variables wars with common sense." Judge Rakoff made his point as follows: "Nowhere is this more obvious than in this very case, where the Sentencing Guidelines assign just 2 points to Mr. Gupta for his abuse of a position of trust--the very heart of his offense--yet assign him no fewer than 18 points for the resultant but unpredictable monetary gains made by others, from which Mr. Gupta did not in any direct sense receive one penny."