Insider trading cases have been tricky to prove due to the personal benefit test. The Supreme Court hasn't provided clear guidance, leading to uncertainty in defining insider trading. However, a potential solution may lie in using a different law, 18 U.S.C. §1348, which could simplify bringing insider trading cases by focusing on securities fraud instead. This approach may bypass the complexities of the personal benefit test and rely on more general fraud-based elements. The application of this law to insider trading is still uncertain, raising questions about whether the traditional insider trading criteria should be applied to this new approach.