Court does not need to consider the global economic downturn where ex-hedge fund manager exposed the investors to risks. A former hedge fund manager appealed from a district court conviction and sentencing to 48 months’ imprisonment for securities fraud. The manager contended that the global economic downturn, and not his fraudulent scheme, was the ultimate cause of the victims’ loss and therefore the actual loss attributable to the fraud was US$0. The Second Circuit affirmed, determining that the district court reasonably held that no offset was warranted for losses resulting from changed economic circumstances, as the investors would not have been exposed to the risks had the manager not fraudulently induced them into investing. (11/18/2015) Balboa.