Whether the Second Circuit's 'right to control' theory of fraud is a valid basis for a conviction under the federal mail and wire fraud statutes

QUESTION PRESENTED Whether the Second Circuit’s “right to control” theory of fraud — which treats the deprivation of complete and accurate information bearing on one’s economic decision as a form of “property” fraud — is a valid basis for a conviction under the federal mail and wire fraud statutes, 18 U.S.C. §§ 1341, 1343.