Keith M. Rudman - Page 7




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          Stat. 630, we distinguished brokers and investors who were not              
          floor traders, floor brokers, or members of an exchange from                
          commodities dealers.  Among other reasons, Kovner is                        
          distinguishable from the instant case in that the parties herein            
          concede that petitioner was a commodities dealer and that                   
          petitioner at all times remained a member of the CBOT and had the           
          ability to conduct trades on the floor of the CBOT.                         
               To reflect the foregoing,                                              
                                                   Decision will be entered           
                                               under Rule 155.                        































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Last modified: May 25, 2011