Does a remote tippee need to know that the original tipper received personal benefit in return for revealing inside information?

We have yet to decide whether a remote tippee must know that the original tipper received a personal benefit in return for revealing inside information. Compare United States v. Rajaratnam, 802 F. Supp. 2d 491, 499 (S.D.N.Y. 2011) (holding that a remote tippee must know that original exchange was given in exchange for benefit), with United States v. Newman, No. 12cr121, 2013 WL 1943342 at * 2 (S.D.N.Y. May 7, 2013) (holding that remote tippee need only know that tipper breached a fiduciary duty and not have specific knowledge that tipper received a personal benefit). But that question is not at issue in this case because the district court's instruction favored the defendant.