 In "Morgan Stanley v. Skowron", 989 F. Supp.2d 356 (S.D.N.Y.2013), applying New York's faithless servant doctrine, the court held that a hedge fund's portfolio manager engaging in insider trading in violation of his company's code of conduct, which also required him to report his misconduct, must repay his employer the full $31 million his employer paid him as compensation during his period of faithlessness.