On June 23rd, the Ninth Circuit reinstated a jury verdict finding that two former Gateway, Inc. executives engaged in accounting misrepresentations in violation of the securities laws, finding that substantial evidence supported the jury's verdict that defendants at least recklessly misrepresented Gateway's revenue. The court also reversed the entry of summary judgment dismissing the SEC's claims against a third Gateway executive, finding that genuine issues of material fact exist regarding whether that defendant knowingly misrepresented Gateway's financial growth. SEC v. Todd.