Opinion by Judge THOMPSON; Partial Dissent by Judge REINHARDT.
DAVID R. THOMPSON, Circuit Judge:
Noble Metals International, Inc.; Moorgate Ltd.; Richard Schulze, a principal of Moorgate and assistant secretary of Noble; and Richard Portaro, Jr., Moorgate's former sales manager, (collectively defendants) appeal the district court's grant of summary judgment in favor of the Commodity Futures Trading Commission (the CFTC or the Commission). The district court...
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