The Securities and Exchange Act of 1934 makes it unlawful for “any person, directly or indirectly, by the use of any means or instrumentality of interstate commerce or of the mails” to use or employ “any manipulative or deceptive device or contrivance” in connection with the purchase or sale of securities in contravention of the rules and regulations of the SEC.1  Examples of instrumentalities include emails, interstate telephone calls, and use of a national securities exchange to execute a trade.

1 15 USC § 78j.

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