On December 10th, the Ninth Circuit reversed the conviction of Prabhat Goyal, the CFO of Network Associates, Inc., formerly known as McAfee, on securities fraud and making false statement charges arising from an alleged accounting fraud. The Court held that that the prosecution offered no evidence adequate to prove that any GAAP violations materially affected the revenue that NAI reported; failed to prove that NAI violated GAAP; and failed to prove Goyal's knowledge of a GAAP violation. In a stinging concurrence, Chief Judge Kozinski criticized Goyal's prosecution as a stretch beyond proper bounds and urged the government to proceed more cautiously in the future. U.S. v. Goyal.