The Supreme Court held in Skilling that honest services fraud under Section 1346 is defined by pre-McNally case law on bribes and kickback schemes. Whether this provides any more clarity and notice than before the Court's decision is an open question. The lengthy opinions do not define what constitutes bribery or a kick back scheme. Also left open is whether in fact a breach of fiduciary duty underlies these concepts and if so, the source of this law. Join Tom Gorman, a partner at Porter Wright Morris & Arthur LLP, and Frank Razzano and Jeremy Frey, both partners at Pepper Hamilton LLP, for this important program, which analyzes the High Court's honest services decision and explores key questions every practitioner must analyze when representing a client involving an honest services charge.