By extracting a $13 million penalty and imposing tough restrictions on future oil trading by Arcadia and others, the U.S. Commodity Futures Trading Commission (CFTC) this week sent a powerful signal that laws against market manipulation still have teeth. The case challenges a now famous view expressed in 1991 by commodities lawyer Jerry Markham that manipulation of commodity futures prices had become an unprosecutable crime. "Under present law the crime of manipulation is virtually unprosecutable, and remedies for those injured by price manipulation are difficult to obtain," Markham wrote in an article published in the Yale Journal of Regulation.