United States v. Gregg Smith

CourtCourt of Appeals for the Seventh Circuit
DecidedAugust 20, 2025
Docket23-2840
StatusPublished

This text of United States v. Gregg Smith (United States v. Gregg Smith) is published on Counsel Stack Legal Research, covering Court of Appeals for the Seventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Gregg Smith, (7th Cir. 2025).

Opinion

In the

United States Court of Appeals For the Seventh Circuit ____________________ Nos. 23-2840, 23-2846 & 23-2849 UNITED STATES OF AMERICA, Plaintiff-Appellee, v.

GREGG SMITH, MICHAEL NOWAK, and CHRISTOPHER JORDAN, Defendants-Appellants. ____________________

Appeals from the United States District Court for the Northern District of Illinois, Eastern Division. Nos. 1:19-CR-00669-1, 2, 4 — Edmond E. Chang, Judge. ____________________

ARGUED SEPTEMBER 5, 2024 — DECIDED AUGUST 20, 2025 ____________________

Before EASTERBROOK, KIRSCH, and KOLAR, Circuit Judges. KIRSCH, Circuit Judge. Gregg Smith, Michael Nowak, and Chrisopher Jordan were precious metals futures traders who manipulated the market through an unlawful practice called spoofing, meaning they placed deceptive orders they in- tended to cancel to push the market price a certain direction. At trial, they were all convicted of various crimes in connec- tion with this practice. They appeal their convictions on 2 Nos. 23-2840, 23-2846 & 23-2849

multiple grounds. Finding none of their challenges persua- sive, we affirm across the board. I A Gregg Smith, Michael Nowak, and Christopher Jordan once traded precious metals futures contracts on commodities exchanges operated by the Chicago Mercantile Exchange Group (CME). They each employed a fraudulent scheme, known as spoofing, to game the system and manipulate the prices of the precious metals futures they traded. Spoofing is possible because of the nature of commodities futures trading. A futures contract is a legally binding agree- ment to buy or sell a commodity at an agreed-upon price on an agreed-upon future date. Commodities futures traders use an electronic platform known as Globex to access CME- operated exchanges. These traders place bids to buy, or offers to sell, a certain number of futures contracts on Globex at a specified price or level. Trading on Globex is anonymous, and while some traders employ computer algorithms to place or- ders, others enter their orders manually, as Smith, Nowak, and Jordan did. Globex also permits traders to cancel an or- der, or an unfilled portion of an order, any time before it is executed. The price of futures contracts is determined by supply and demand: the price will increase if there is more demand than supply for a product, and vice versa. But a fundamental as- sumption on CME exchanges is that every order represents a legitimate, bona fide order placed with the intent to trade. Each order visible on Globex therefore impacts the market by conveying an intent to participate in it at a particular price. Nos. 23-2840, 23-2846 & 23-2849 3

Today, Globex shows every available order, but when Smith, Nowak, and Jordan were traders, it displayed only the ten best bids and the ten best offers at any time. And because larger quantity orders will have a greater effect on price than smaller orders will, Globex allows traders to break up larger orders into a number of smaller ones by placing so-called ice- berg orders. In this way, iceberg orders enable traders to con- ceal the true size of their order. Although these features were designed to mitigate the impact that large orders would have on the market price, they paved the way for fraudulent schemes to manipulate the market—especially spoofing. A spoofing trader places large orders that he does not in- tend to execute, driving the price in a more favorable direc- tion by communicating false information that deceives the marketplace about actual supply and demand. This typically involves four steps. First, the trader places an order, often an iceberg order, that he genuinely intends to trade. Second, the trader places a visible spoof order on the other side of the mar- ket. The trader never intends to trade this order; rather, it is designed to push the market price to the benefit of the legiti- mate order. For instance, if a trader wants to buy at a price below the market, he will place a large sell order at a low price (or a series of smaller sell orders at descending prices) to push the market down. Third, the market reacts to the illusion of market activity generated by the spoof order, allowing the trader to execute the genuine order at his desired price. Fourth, the trader cancels the spoof order before it can be filled. CME rules have long prohibited spoofing. In particular, CME Rule 432 prohibits traders from manipulating or at- tempting to manipulate “prices of exchange futures or 4 Nos. 23-2840, 23-2846 & 23-2849

options contracts”; employing or attempting to employ “any manipulative device, scheme or artifice to defraud”; and pur- chasing or selling or offering to purchase or sell “exchange futures or options contracts or any underlying commodities or securities for the purpose of upsetting the equilibrium of the market or creating a condition in which prices do not or will not reflect fair market values.” Accordingly, the defend- ants’ employers have policies prohibiting spoofing, both ex- pressly and implicitly as a form of market manipulation. B Nowak and Smith worked at JPMorgan from 2008 to 2016. Nowak was a managing director who ran the precious metals trading desk, splitting his time between New York and Lon- don. Smith was an executive director and sat next to Nowak in the New York office. He joined JPMorgan after it acquired Bear Stearns in 2008. Jordan worked as a precious metals trader in the New York office between 2006 and 2009. After JPMorgan terminated him in 2009, he moved to Credit Suisse, where he worked from March to August 2010. On multiple occasions, Smith, Nowak, and Jordan each placed orders mirroring the trading pattern of spoofing. That conduct eventually led the government to indict them for var- ious spoofing-related crimes. Smith and Nowak were each charged with attempted price manipulation, 7 U.S.C. § 13(a)(2); wire fraud, 18 U.S.C. § 1343; commodities fraud, 18 U.S.C. § 1348(1); and violating the anti-spoofing provision of the Dodd-Frank Act, 7 U.S.C. §§ 6c(a)(5)(C) & 13(a)(2). Jordan was charged with wire fraud, 18 U.S.C. § 1343. All three were charged with conspiracy, but none were convicted. Nos. 23-2840, 23-2846 & 23-2849 5

1 Smith and Nowak were tried together. They did not mean- ingfully contest that their trading activity resembled the four- step pattern of spoofing. Rather, they argued that their trad- ing was fully consistent with innocent behavior and that the government could not prove the requisite intent. During a three-week trial, the government presented substantial evi- dence to the contrary. Below, we summarize the evidence rel- evant to this appeal. Kumar Venkataraman, a finance expert, explained how Smith’s and Nowak’s trading patterns and resultant fill ratios aligned with the typical spoofing pattern. In a set of 100 trad- ing episodes identified, Smith’s spoof orders had a fill ratio (meaning the percentage of contracts filled) of 0.18%, com- pared to a 79.11% fill ratio for his genuine orders. Nowak’s fill ratios were similar: 0.22% for his spoof orders and 90.11% for his genuine orders. The defendants’ broader trading showed this pattern, as well.

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