Mealey's (May 22, 2020, 1:27 PM EDT) -- NEW YORK — A federal district court did not err in concluding that although an investment adviser was a statutory insider of Sears Holding Corp. and subject to the short-swing profit rule its clients were not, and, as a result, the clients were not liable for alleged federal securities rule violations, a Second Circuit U.S. Court of Appeals panel ruled May 20 (Aaron Rubenstein v. Rofam Inv. LLC, No. 19-796, 2nd Cir., 2020 U.S. App. LEXIS 16114)....