- Daniel Ravicher had accused Carl Icahn and three large banks of helping Herbalife (HLF +3.8%) perpetuate a pyramid scheme after losing more than $75K trying to piggyback on Bill Ackman's short thesis.
- The judge ruled Ravicher could win only if he could show his purchase of put options imposed a duty on Icahn and the banks not to help Herbalife. "That is not only a counter-intuitive proposition, it violates a principle (volenti non fit injuria) that one who knowingly and voluntarily risks danger cannot recover for the resulting injury."