http://www.chron.com/disp/story.mpl/business/7077853.html
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“The Government charged Skilling with conspiring to de-fraud Enron’s shareholders by misrepresenting the company’s fiscal health to his own profit, but the Government never alleged that he solicited or accepted side payments from a third party in exchange for making these misrepresentations,” the court said.
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When you are using the system to rip people off, you don’t *need* a third party. Anyone will do.