In a recent decision, a federal judge in New York refused to dismiss an SEC lawsuit against Steven M. Gallagher, a Twitter user accused of manipulating penny stocks. The SEC alleges that Gallagher, using his Twitter account, promoted certain stocks without disclosing his intent to sell his shares, an act known as "scalping." Judge P. Kevin Castel ruled that Gallagher had a duty to disclose his holdings once he publicly recommended these stocks, as his omissions could mislead reasonable investors.