The U.S. Court of Appeals for the Second Circuit affirmed the conviction of a securities fraudster in a summary order in United States v. Fleishman. The summary order dismissed each of the defendant's arguments with little or no analysis, including his attack on the legality of the government's wiretap evidence. Given the importance of that issue in the pending appeal of Raj Rajaratnam, who also attacked the use of wiretaps in his case, some thought the Fleishman appeal could be a bellwether. But given the short shrift paid to the issue (and the dissimilarity of the attack on the wiretaps), nothing can really be gleaned from this order.