Article

When Activist Short Selling Becomes Market Manipulation

New York Law Journal
By Celia Cohen, Michael Berry, and Thamanna Hussain
July 1, 2026

Ballard Spahr Litigation Department attorneys Celia A. Cohen, Michael Berry, and Thamanna Hussain wrote for the New York Law Journal about what the recent criminal conviction of Citron Research's founder Andrew Left means for other activist short sellers, and draw on recent Securities and Exchange Commission actions as well to provide a practical compliance roadmap for market participants navigating the line between legitimate market commentary and manipulation.

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