On August 31, 2011, the United States Securities and Exchange Commission (SEC) continued its war on “family and friends” insider trading when it filed a civil complaint in the United States District Court for the District of New Jersey against Clay Capital Management, LLC; one of its founders, James F. Turner, II; his neighbor, Mark Durbin; and Mr. Turner’s alleged accomplices, Scott Vollmar and Scott Robarge (together, defendants).  The complaint accuses Turner of insider trading in early 2008 on information obtained from his brother-in-law Vollmar, a director of business development for Autodesk, Inc., and his college friend Robarge, a recruiting technology manager for Salesforce.com, Inc.  It also accused Turner of passing that information to the Clay Capital Fund, LP (the Fund) and other family members and friends, and accuses Vollmar of doing the same for his neighbor Durbin.  The complaint does not accuse his unnamed associates, including his partners in the Clay Fund, of participating in or having any knowledge of the scheme.  The accusations again Robarge and Durbin have already resulted in settlements with the SEC.  We detail the allegations in the complaint, which provide further insight into what information flows among friends and family constitute insider trading in the view of the current SEC Enforcement Division.