Mealey's (February 3, 2020, 11:30 AM EST) -- PHILADELPHIA — A Third Circuit U.S. Court of Appeals panel on Jan. 30 ruled that a federal district court did not err in ruling that a defendant in a securities fraud criminal suit failed to sufficiently establish beyond a preponderance of the evidence “a lack of knowledge” of a federal securities statute when he violated it by participating in an illegal short-selling scheme (United States v. Steven Fishoff, No. 18-3549, 3rd Cir., 2020 U.S. App. LEXIS 2928)....