Former McKinsey & Company CEO Rajat Gupta, convicted of three counts of securities fraud and one count of conspiracy related to an insider trading scheme in 2012, is scheduled to be released from federal prison in March 2016. Gupta’s fairly imminent release did not stop him from moving to vacate his conviction, as others have done, under the Second Circuit’s landmark Newman decision. Last week, however, Judge Jed Rakoff of the SDNY ruled that the Newman decision does not apply to the facts in Gupta’s case.