In 1997, the U.S. Supreme Court adopted the misappropriation theory of insider trading in United States v. O'Hagan,[27] 521 U.S. 642, 655 (1997). O'Hagan was a partner in a law firm representing Grand Metropolitan, while it was considering a tender offer for Pillsbury Company. O'Hagan used this inside information by buying call options on Pillsbury stock, resulting in profits of over $4.3 million.