AN OPEN LETTER TO NEW YORK ATTORNEY GENERAL ANDREWCUOMOAugust 17, 2009DEAR MR. CUOMO:I would like to introduce you to Pete Richichi. Mr. Richichi is the Chief OperatingOfficer at Wynit Distribution, one of the country's largest distributors of consumerelectronics. Wynit distributes myriad products. Most notably, Wynit is a majordistributor of GPS location device made by the company Garmin (GRMN). In fact,Wynit is one of the two largest distributors of these products at present with a widerange of customers including some of the largest consumer electronics chains aswell as e-commerce companies and independent retailers.Why should this concern you? Because Mr. Richichi is also avery active

consultant working at the Gerson Lehrman Group (GLG). He's listed as among

their Top 5% of contributors, which means that GLG's hedge fund analyst clientslike him very much indeed. GLG is a so-called "expert network". You likely knowwhat an expert network is (since yourpredecessor Elliot Spitzer had started

investigations into several expert networksand theU.S. Senate has demanded

investigations of GLG's role in helping doctors communicate what was alleged to

be inside information to hedge fund analysts). But for the masses I'll explain. An

expert network is an informal group of industry experts who work as ad-hoc paidconsultants. The consultants function as an on-call answer service for large hedgefunds and other Wall Street investors. If an analyst at a multi-billion dollar hedgefund wants to find out how a particular Garmin SKU is selling or perhaps when anew Garmin product will be launched, they contact their Gerson LehrmanRepresentative who, in turns, calls Mr. Richichi.Naturally, such consultants are paid very well for their services. I'd wager Mr.Richichi is clearing $400 to $500 per hour for his services. For those sorts of prices, the information had better be good. And as someone who formerly spokewith expert network consultants on a regular basis in a past life, I can assure youthe information is extremely good. So good that it often constitutes information notyet in the public realm, information that can play a key role in determining whetherto buy or sell a security.Is this insider information? I would not be able to make such a legal distinction.But consider the following case. In its latest quarterly report,Garmin announcedunexpectedly strong earnings numbers, causing shares to spike nearly 20% in a