According to a recent study by NERA Economic Consulting, the SEC is on pace to settle with more defendants this year than in any year since 2005. This increase is attributable to heightened settlement activity with individuals, particularly for allegations related to insider trading and Ponzi schemes. In the first half of fiscal year 2012, the SEC settled 286 cases with individuals, putting it on pace for 572 settlements in 2012. The median settlement value with individuals continued to follow the upward path observed since fiscal year 2010, while the median value of settlements with companies declined after reaching a record value in 2011. The largest settlements in the first half of 2012 are the highly publicized settlements with Citigroup Global Markets, Inc. ($285 million), still under appeal after being rejected by Judge Jed Rakoff, and Raj Rajaratnam ($92.8 million).