According to federal charges filed by the U.S. Attorney in the District of New Jersey, on or about Dec. 5, 2005 — the date that Kluger joined Wilson Sonsini — Kluger signed the firm’s written policy prohibiting insider trading. Among other things, the policy:
• Stated that “no employee shall engage in any transaction involving the securities of a company about which the employee has Material, Non-Public Information obtained through the Firm.”
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