Robert A. Katzmann, the chief circuit judge who wrote the opinion for two of the judges on the panel (the third wrote a dissent), didn't need to consider the nuances of the relationship and how Dr. Gilman might have benefited (or suffered) emotionally, because the two had a straightforward financial relationship: Dr. Gilman earned hundreds of thousands of dollars in consulting fees from Mr. Martoma, and so he had every reason to ingratiate himself by divulging the information.