How have courts considered the "right to control" aspect of mail fraud?

In United States v. Wallach , 935 F.2d 445 (2d Cir. 1991), we first addressed the extent of the "right to control" aspect of mail fraud. Id. at 46263. We explained that "application of the [right to control] theory is predicated on a showing that some person or entity has been deprived of potentially valuable economic information." Id. "Thus, the withholding or inaccurate reporting of information that could impact on economic decisions can provide the basis for a mail fraud prosecution." Id. at 463.