To buttress the argument, the government cited instant messages that a recently 
hired SAC employee sent Mr. Cohen in July 2009. The employee informed Mr. Cohen 
that, due to "recent research," he planned to bet against Nokia's shares. The 
employee apologized for being "cryptic," explaining that SAC's compliance chief 
"was giving me Rules 101 yesterday – so I won't be saying much," adding that 
the warning was "scary."

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