Following a trial in the Southern District of New York, a federal judge ruled that Citibank is not entitled to recover approximately $500 million dollars of the $900 million the bank mistakenly sent to lenders of Revlon. The ruling turned on the conclusion that the recipients neither knew nor reasonably should have known that the payment was made in error.

On August 11, 2020, Citibank, acting as the administrative agent for a syndicated loan to Revlon, mistakenly sent approximately $900 million dollars to a group of Revlon’s lenders. Realizing its massive error, the following day Citibank requested the lenders return the funds and many lenders complied. A group of ten lenders who were owed approximately $500 million of the $900 million, however, refused to return the funds arguing that they were indeed owed the money they received.

The error stems from a $7.8 million interim interest payment that Revlon intended to pay to its lenders through Citibank. The interim interest payment was part of a complex restructuring of Revlon’s loan whereby certain lenders, but not others, would be repaid. To effect this interest payment, Citibank’s internal system required the entire loan to be constructively paid off and for the principal balance to be paid to an internal Citibank “wash account.” Citibank’s complex payment system, however, caused its operations employees to mistakenly believe they indeed directed the principal payment to the internal wash account; in fact, the entire principal balance was sent out the door to Revlon’s lenders. Because Revlon only provided $7.8 million to Citibank to pay the interim interest payment, the $900 million sent was from Citibank’s own funds.

The lenders who refused to return the $500 million prevailed in court by successfully arguing a “discharge-for-value” defense. Under New York law, a creditor may retain funds inadvertently paid by a third party to satisfy a debt if the creditor did not have notice of the third party’s mistake. The arguments at trial focused on whether the recipients should have known that the payments were made in error and thus had notice of Citibank’s mistake. Here, the Revlon lenders pointed out that the payments made by Citibank were for the exact amounts owed––to the penny––to each lender. Thus, they argued that it was reasonable for them to assume that the wire was made to repay Revlon’s debt and that it was not made in error. The court further agreed that the alternate assumption the lenders could have made––that a sophisticated financial institution like Citibank mistakenly wired almost one billion dollars to lenders––was less plausible.

Curiously, jokes made at Citibank’s expense by the lenders also weighed in favor of the lenders. The opinion lists a number of chats and communications from employees at the lenders poking fun at Citibank for one of the largest banking errors in history. (“I feel really bad for the person that fat fingered a $900mm erroneous payment. Not a great career move.”) Notably, the teasing only began after the lenders received Citibank’s demand for return of the funds. The court considered the absence of these jokes before Citibank’s demand as evidence that lenders were initially not on notice that the wire was made in error. Citibank announced its intention to appeal the district court’s ruling.

Minneapolis is yet another city that has taken the necessary step to ban facial recognition software for police use. After a series of reports over the last five years provided overwhelming evidence that the use of facial recognition software disproportionately negatively impacts minorities, several cities implemented this critical step in their long-term fight against aggressive policing. However, Minneapolis failed to enact policies prohibiting the use of this software for “non-police uses” or by “other local law enforcement who operate in the city.” How does this affect the prospective impact of a seemingly progressive policy?

What is facial recognition software?

Originally “developed in the early 1990s,” this software sifts through images of individuals from various sources, including “social media profiles and driver’s licenses,” employs face detection algorithms to “extract features from the face . . . that can be numerically quantified” to determine the level of similarity between the faces. These algorithms are consistently evolving through training processes, learning which are “the most reliable signals” that diagnose similarity.

Long before technology existed to automate this process, the same principles underlying facial recognition software were employed to confirm individual identities and “identify an unknown face.”

How do facial recognition software bans fit within a larger series of reforms against aggressive police tactics? What role does the private sector play?

The ban in Minneapolis arrives after a rather accelerated dismissal of City Council promises made to fundamentally alter the corrupt policing system. These promises included defunding the police – terminology that was quickly retracted and explained away just months later. It is relatively unclear what catalyst led to the proposal and widespread support for this ban after such an extensive retreat from previously planned reform. Some point to the action taken by several cities in the Fall of 2020 and encouragement from prominent organizations like the American Civil Liberties Union (ACLU) to prohibit this technology, while others acknowledge the “dystopian” nature of the tracking system and its propensity “for abuse;” but at the very least,  it is certainly a positive step towards eliminating the systemic injustice.

While the ban may signal progress, it is crucial to acknowledge not only the delay in its implementation, but also the lack of widespread application and permissible use of this software by other local law enforcement agencies and private companies.

What are the legal implications of face recognition software use?

Many have discovered the face recognition software encounters difficulties “identifying people of color” which “could widen existing criminal justice disparities.” Additionally, the software draws on historical data from law enforcement sources, which have a proven history of racial biases. Finally, the software filters through all this data “without people’s consent,” presenting issues of privacy violation.

Georgetown University’s “The Perpetual Line-Up” report identifies at least four major areas of legal concern: violation of Fourth Amendment rights; encroachment of First Amendment rights to free speech and assembly; disproportionate and unequal impact on racial and ethnic minorities; and invasion of privacy rights given the lack of transparency and requests for consent from the public.

Other individual cities have enacted similar bans. What is the effort at the federal level?

The National Biometric Privacy Act of 2020 in the Senate, and the Stop Biometric Surveillance by Law Enforcement Act in the House were both introduced last year to effect widespread impact against the use of racially-biased and inaccurate software. While this proposed legislation illustrates eagerness for change at the federal level, tackling the use of the technology by both the public and private sectors, the bills have yet to move past the initial introduction stage or gain critical bipartisan support.

What does the future of facial recognition software look like for our legal system?

Some believe “police use of face recognition is inevitable,” and helps to identify individuals who may “otherwise have gone undetected.” While there may be truth underlying these assertions, opponents argue the technology has yet to advance to such a level where the community can be confident in the objective use of the system without racial bias or problems of inaccuracy.

Do we as a society continue employing a system flooded with perturbing defects with the knowledge of its constant evolution, ideally to a place of flawless implementation? Or do we protect our country’s minorities and our individuals’ rights to privacy and ban further use of inherently problematic software, at a federal level, until proof of the elimination of bias and increase in accuracy levels?

Following twelve months of significant financial losses, Uber is now facing serious regulatory challenges across Europe that threaten to significantly increase its operating costs. The company’s future viability may now depend on the extent to which it can dominate in markets outside the continent.

In a landmark decision last month, the Supreme Court of the United Kingdom ruled that Uber must consider its drivers as “workers” entitled to minimum wage and vacation time. The court unanimously dismissed Uber’s claim of being a booking agent that hires self-employed contractors. Instead, the justices found that drivers are subordinate and dependent, because Uber unilaterally sets contract terms and conditions, dictates how much drivers earn by setting fares, and is free to terminate the relationship if passengers consistently rate driver performance too low. Most dramatically, the court ruled that Uber must consider its drivers as “workers” from the minute they log on to the app, until they log off.

The Supreme Court’s ruling comes after nearly five years of legal battles between Uber and a small group of former drivers. James Farrar and Yaseen Aslam first took the company to an employment tribunal back in 2016 and successfully argued that they “worked” for Uber. The company appealed, but the Employment Appeal Tribunal upheld the ruling. In 2018 the company took the case to the Court of Appeals but lost again. Friday’s ruling was Uber’s final appeal. Although the decision initially affects only the 25 drivers who brought cases, the ruling is expected to set precedent for the remaining 60,000 drivers across the UK.

Although Uber is no stranger to legal problems in the UK, having been twice banned from London over safety concerns, experts say this ruling could be a “nightmare” for the company. Uber is still not profitable, and Covid has strained their finances further; in 2020 the company reported a net loss of $6.8 billion. Increased labor costs in a top five market could push profitability even farther away. The ruling might also revive discussions about whether Uber should now be classified as a transport provider in the U.K. (rather than as a booking agent), and thus be liable for 20% VAT (Value Added Tax) on fares. Moreover, now that drivers become workers upon logging into the app, Uber will need to adjust its systems to avoid oversupplying markets with too many idle vehicles. The market certainly seems nervous; Uber’s share price dipped 1.6% after the ruling.

The UK Supreme Court decision is not an anomaly. Recently, countries across Europe have been moving towards protecting and strengthening workers’ rights in the gig economy. Last year, France’s top court ruled that an Uber driver did not qualify as self-employed, and earlier this year judges in the Netherlands and Spain ruled that some of their cycle couriers and food delivery riders are employees. Last month Uber released a white paper urging Europe to adopt a Proposition 22-style “third way”, where drivers remain contractors but have access to benefits funds. So far, the European Union isn’t listening. At the end of February, the European Commission began a six-week public consultation period seeking feedback from trade unions and employer groups on how to better protect gig-worker rights. The EU is even said to be considering relaxing its competition laws to allow gig workers to collectively bargain. Increasingly, some companies do not believe that the freelance model is sustainable in Europe. Dutch food delivery company Just Eat Takeaway stopped using gig workers on the continent, but will continue to do so in the U.S.

Back in the U.K., Uber is seeking to narrow the Supreme Court’s ruling, arguing that it has made a number of changes to its business since 2016, and that the ruling should not apply to all drivers. However, it is more likely that the decision will have very broad implications, challenging similar gig economy companies across the country to make changes to their business models before drivers and couriers bring suit. Will Uber stay in the U.K.? Departure is unlikely; Uber dominates the country’s rideshare market. More likely, the company will alter its business model, possibly passing higher operational costs onto customers. Regardless, last month’s ruling will certainly strengthen and accelerate Uber’s pre-emptive efforts to protect itself from regulatory risks in markets outside Europe.

In the span of less than a year, the new audio-only social media platform, Clubhouse, increased its valuation tenfold. At the end of spring 2020, with just 1,500 users, Clubhouse was valued at $100 million after receiving funding from one of the biggest VC firms in Silicon Valley, Andreessen Horowitz. In January 2021, the same investors led a financing round that valued Clubhouse at $1 billion — making the social media startup who currently boasts roughly 2 million weekly users a certified unicorn.

So, what makes Clubhouse so different from other social media platforms? Clubhouse lets users connect via audio chat rooms which are essentially live podcasts that can allow other users to join in on the conversation to discuss anything and everything. Some users have accredited Clubhouse’s success to its ability to create an environment that is more personal than text-only platforms but not as invasive as video chat.

At this point, you might be wondering why you’ve never heard of this app before. Well, that’s because Clubhouse is exclusively on iOS and the only way to join is by being invited by other users. Once a user joins the app, they receive invitations of their own to give out. Clubhouse does let non-users reserve usernames, however, and there are invitations being sold on sites like Etsy and eBay. It’s likely that the app will eventually open up its doors to the public — and even develop an Android version — but, as of now, the app remains closed off to the unlucky masses who are unable to obtain an invite on their iPhones.

Clubhouse’s success has not gone unnoticed. In the social media world, imitation is the greatest form of flattery, and Clubhouse should feel quite flattered as Twitter, Facebook, and even Mark Cuban attempt to develop audio-based chat rooms of their own. Twitter is currently in the process of developing its voice-chat rooms called “Spaces” in order to keep up with the rise in popularity of Clubhouse.

To be fair, Clubhouse is far from the first to create a social media platform centered around voice chat. Discord, which gained its popularity by catering to the gaming community, has been a major player in the audio chat room space for some time. Discord has significantly grown its usership since its initial release in 2015, and recently doubled its valuation to $7 billion in a Series H round at the end of 2020. The major success of audio-based platforms like Clubhouse and Discord may be a sign of what direction social media will be taking in the years to come.

Despite not being the first or biggest audio-focused social media platform, Clubhouse certainly has momentum on its side — and sometimes that’s all it takes. The app has received so much hype, in fact, that the Economist reported that after Elon Musk announced on Twitter that he would be joining Clubhouse “the share price of Clubhouse Media Group soared by 117%.” Unfortunately for those investors, Clubhouse Media Group is a completely different company located in China. While Clubhouse, the social media platform, is not yet a publicly traded company, the level of attention brought to the app by its high-profile users such as Mark Zuckerberg, Drake, and Robinhood CEO Vlad Tenev is sure to help the startup raise cash.

Clubhouse is likely to bring in even more celebrities and influencers as it plans to add monetization for content creators through subscriptions, tipping, and ticketed events. But with more users comes more problems. Live audio makes moderating and regulating content all the more challenging — especially as the risk of hate speech, abuse, and misinformation increases with every new user. Paul Davison, the CEO of Clubhouse, has stated that Clubhouse has strict guidelines on hate speech and trained moderators who can step in and end a conversation that violates Clubhouse policies. However, moderating these talks are easier said than done as many users have noted various instances of hate speech and misogyny taking place on the app.

Clubhouse has a promising future, but it still faces many challenges as it avoids becoming the voice chat version of Parler all while competing with well-established platforms like Facebook and Twitter who are capable of swallowing their competition.

The coronavirus pandemic has exacerbated inequality in the workforce for millions of American women. First there was that alarming statistic: of the 140,000 jobs lost last December, all of them were held by women. Specifically, women lost 156,000 jobs while men gained 16,000.

While economists warn against putting too much stock into a single month, women ended 2020 with 5.4 million fewer jobs than they had in February, before the pandemic began. Comparably, men lost 4.4 million jobs over that same period.

There are additional significant racial disparities among women, with the pandemic disproportionately impacting women of color in the workforce. Latinas currently have the highest unemployment rate at 9.1%, followed by Black women at 8.4%, while white women have the lowest unemployment rate at 5.7%.

There are several factors contributing to this inequity. During a virtual panel with members of Congress, Representative Rosa DeLauro put it this way: “women are not opting out of the work force, they are being pushed by inadequate policies.”

Women, especially Black and Latina women, disproportionately work in the industries that have laid off or furloughed more employees in response to covid-19. The three major sectors experiencing these job losses are education, hospitality, and retail.

Women are also more likely to work in roles that lack flexibility. Black and Latina women specifically are disproportionately impacted, as they more frequently work in roles that lack paid sick leave and the ability to work from home.

The closure of schools and childcare centers also disproportionately impacted women. Parents were forced to monitor the home schooling of the children, and for the vast majority, the burden fell on the mom. In September, when the school year resumed, four times more women than men dropped out of the labor force. For women with jobs that lacked flexibility, the increased caregiving responsibilities forced them to exit the workforce.

Women are also disproportionately owners of small businesses that benefit from foot-traffic, and have therefore been disproportionately negatively impacted by the pandemic. During the pandemic, women-owned business have had larger net losses in their headcounts and slower recoveries than men-owned businesses.

Economists have suggested that unless significant action is taken, this loss will result in significant damage to the economy and to gender equality in the workforce for decades to come.Earlier this month, Vice President Kamala Harris wrote an op-ed on the exodus of women from the workforce, describing the situation as a “national emergency.” The Biden administration has proposed a plan to address the needs of women workers, including $3,000 in tax credits issued to families for each child, a $40 billion investment in child care assistance and an extension of unemployment benefits. The administration’s relief proposal would also focus on reopening K-12 schools, a major component of child care.

The House Budget Committee is considering the legislation today, with the full House possibly passing the legislation as soon as next week. Whether the legislation will survive through the Senate, where Democrats can’t afford to lose a single vote from their party, remains to be seen.

The pandemic we are currently experiencing has created unprecedented market conditions with unpredictable results. In one of those events, seemingly out of nowhere, a company that many institutional investors were betting would end up bankrupt surged 1000% within a period of two weeks. This stirred up a frenzy of retail investors, united by the common cause against the institutional investors who had “shorted” the stock, creating a highly polarized environment with social underpinning. These events activated the reflexes of the trading mechanism’s cogs in an effort to control the irrational price action under the pretense of the “safety of retail investors.” Several brokers halted intraday trading of GameStop, allowing only the sale of the stock, but in later days slowly accepted a reduced number of shares to be traded. The majority of media outlets focused on the coordination of millions of retail investors flocking to GameStop shares, however, the brokers are currently being investigated for market manipulation.

The story, though, goes deeper. Why would a broker risk its reputation and legal sanctions to manipulate the market and keep a surging stock low? The main broker at issue is Robinhood: one of the fastest growing brokers that apparently is striving to “democratize trading” and also serves the highest market cap of traders instigating the surge of GameStop. However, the profit centers of Robinhood are relatively opaque as they advertise themselves as a zero-fee broker. The way Robinhood makes their revenue is by payment-for-order-flow (PFOF), which essentially means that they sell the market moves of the (retail) investors on its platform to interested parties, usually institutional investors. One of these institutional investors is Citadel, which constitutes 40% of Robinhood’s total revenue. Things got more complicated when Citadel invested $2bln in equity of Melvin Capital amidst the GameStop frenzy. Melvin Capital was one of the main “short” sellers of GameStop, which resulted in a 53% loss of the total value of the firm that equated with the amount Citadel invested. This points towards a conflict of interest between Robinhood, Citadel and Melvin Capital, and any regulatory action for the benefit of retail investors must take place by a regulatory authority such as the SEC.

Things got even more complicated: the CEO of Robinhood, Mr. Tenev, in an interview with Elon Musk highlighted that it was not his choice to halt trading, but rather the National Securities Clearing Corporation’s (NSCC) choice. NSCC is a corporation that serves to make clearing of orders easier and more effective, but also provides risk management to brokers. As Mr. Tenev explained, the NSCC called him at 3AM demanding $3bln in cash to be transferred to them to balance the outstanding orders and the cash collaterals. It is worth noting that Robinhood is valued at $5bln and has received $2bln in VC funds. This suggests that $3bln would be an impossible amount for Robinhood to come up with. Mr. Tenev mentioned that after negotiations and implementing the trading halt they managed to agree to $700mln.

As it seems, the story of the rise and fall of GameStop stock is complicated and demonstrated a weakness in the system. But some questions remain unanswered: can this private authority – the NSCC – enforce measures to brokers, thus moving the market at will? If so, is the individual who takes the decisions regarding the type of measures absent of conflicts of interest? How are the amounts calculated and how could they flexibly be reduced by 80%? Did executives act on the conflict of interest that arose? Retail investors that feel they were defrauded will continue to demand answers to these questions and more.

As a short-selling investor, you hope that when the price does fall, you can repurchase the shares cheaply, return them to the owner, and pocket the difference. However, this trade becomes extremely risky when the share price rises. This is precisely what happened last week, as GameStop’s shares soared 1700 percent driven by a coordinated effort by retail investors to beat Wall Street at its own game. The event caught extensive media attention, not merely because GameStop’s stock price rapidly increased but because the rise did not reflect any change in GameStop’s lackluster performance. According to GME’s most recently filed 10-Q, its gross profit dropped dramatically from $1311.4 million in 2019 to $810.9 million in 2020. The company recorded a net loss of $295.8 million in the first three fiscal quarters of 2020.

This phenomenon has caused further questioning of the long-accepted efficient capital market hypothesis (ECMH). In the article “The Mechanism of Market Efficiency,” Professor RJ Gilson of Stanford Law School posited that the ECMH is “the context in which serious discussion of the regulation of financial markets occurs.” As a classic footnote of ECMH, Eugene Fama, who won the Nobel Memorial Prize in Economic Sciences in 2013, posited that “in a well-functioning market, the prices of… securities will reflect predictions based on all relevant and available information.” Thus, in a “well functioning” market, prices will “fully reflect” all “available information.” The intuition behind this theory is that the value of financial assets is determined by information. Thus, any “good” or “bad” news relevant to security will cause its price to increase or decrease, respectively. Based on how the asset prices reflect “all the available information,” the theory comes up with three different forms of ECMH: the “weak” form, the “semi-strong” form, and the “strong” form.

Under the weak form of ECMH, the current market price reflects all the past information regarding that security. Thus, if the close price of GME is $18.84 on December 31, 2020, this price should reflect all past information (for example, strong revenue growth or huge economic losses) concerning the stock. For the same reason, the weak form indicates that any short-term stock price will move in a “random walk,” given that the price will be only influenced by tomorrow’s information and tomorrow is always uncertain, so too will be the news.

Under the semi-strong form of ECMH, it further incorporates the reality that information about a security can be publicly available (e.g., the filings disclosed to the SEC, CEO’s marriage story published in the newspaper) and non-publicly available (e.g., confidentiality agreement between employer and employees). In light of the semi-strong form of the ECMH, the price of the security will reflect only all the past information plus the current publicly available information. The reason that the price is able to reflect the upcoming publicly available information is that the traders in the market are constantly seeking out value-relevant information, and in a semi-strong market, it was expected that the new publicly available information would be disseminated quickly. Thus, under the semi-strong form of ECMH, when GameStop’s price peaked at $380 per share on January 27, 2021, it resulted from a fast reflection for the surging purchase demand available to the public eyes.

The strong form of ECMH posits that the current price of a security incorporates all the past and current information regardless of whether such information is publicly available. Thus, under this form, even corporate insiders cannot benefit from insider trading. However, there is little evidence to show that the U.S. securities market is a strong form.

The U.S. capital market, such as NYSE, is deemed as either a weak market or a semi-strong market. However, it would be very much an illusion to conclude that NYSE is either a weak-form market or a semi-strong one. As a typical anomaly to illustrate the deviation, it was found that a stock will have positive current returns if it had positive returns within the past twelve months, while a stock will have negative current returns where it had negative returns within the past twelve months. This finding disobeys the rule of the weak form of the ECMH that the current price will not be influenced by historical information.

A deviation of the semi-strong form of the ECMH is the Long Island case. Long Island is a struggling ice tea company listed on Nasdaq. The company disclosed that its name would be changed to “Long Blockchain Corp.” Immediately after the announcement, its stock price soared nearly 300% before returning to the original price three months later. Compared to this over-reaction case, according to an event study of a pharmaceutical company, the company’s stock price dramatically increased after a release of positive news regarding its cancer-curing drug in the New York Times, even though the same information has already been published in Nature.

Back to GameStop, at first glance, it seems like another deviation of the semi-strong form of the ECMH. However, the lesson behind GME is that market efficiency is not a binary concept but a matter of degree. Thus, for any valuation relying entirely on market prices, it must be carefully examined whether the market is sufficiently efficient to account for the price. This is particularly the case in the current post-COVID-19 period with an extremely low-interest rate, which can trigger the “animal spirits” in investment considerations. This is likely what we have seen with GameStop.

In recent years, veganism has shifted from a fringe movement reserved for hippies, to a mainstream, oft-discussed, and arguably “trendy” diet and lifestyle choice that many food and clothing-providers happily cater to. Not only is this shift in public attitude towards veganism a result of outspokenly vegan celebrities like Ariana Grande, Paul McCartney, and Joaquin Phoenix, but also a universal moral awakening to the environmental impacts of traditional meat production in the agriculture industry, the linkages between an animal-meat-centric diet and a host of serious health complications, and policymakers’ growing focus on the obesity epidemic in the United States. Acclaimed documentaries like “What the Health” and “Cowspiracy,” both available on Netflix, have brought such issues to the forefront of the public’s collective conscience.

This shift in public morality has provoked changes in consumer demand in favor of healthier, more sustainably and ethically produced, and plant-based alternatives to both traditional animal-meat products and classically “American” snacks such as potato chips, Cheetos, and the like. In response, food and beverage giants have steadily increased their plant-based product lines, either through acquisitions of plant-focused startups or the generation of new product lines in-house. Such efforts have seen considerable support in international markets in particular – like China – where demand for vegan alternatives to animal products can scarcely be considered a recent development.

PepsiCo is the latest international food and beverage behemoth to hop on the plant-based bandwagon with its recent announcement of a joint venture with plant-based and sustainable food company Beyond Meat. Along with Impossible, Beyond Meat is one of today’s most popular providers of plant-based meat alternatives, with its wide range of products already distributed in grocers, restaurants, and fast-food chains. Until now, Beyond Meat’s marketing division has been limited primarily to social media campaigns, making its massive footprint on the food and beverage industry all the more impressive.

Beyond Meat’s distribution and marketing practices, however, are about to change and grow drastically through its new alliance with PepsiCo. In fact, hopes thereof were critical driving forces behind the health-focused newcomer’s decision to partner with a giant known for sugary drinks and products that prioritize convenience over quality. The joint venture, coined Planet Partnership, is expected to launch later this year with aims of creating a line of plant-based snacks and beverages that make nutritious alternatives widely available to a broad public, PepsiCo fulfilling its public promises of more sustainable and environmentally-friendly production practices, and encouraging consumers to make “positive choices for both people and the planet,” according to PepsiCo’s global chief commercial officer Ram Krishnan.

In response to public announcements of the joint venture, Beyond Meat’s (BYND) share price shot up 18%, while PepsiCo’s (PEP) remained effectively constant. Though some of this initial excitement in the market response has dissipated, Beyond Meat’s share price remains slightly above that which it had been immediately prior to public disclosure of the deal. While it will be interesting to see what effect, if any, the actual launch of products through the partnership has on both corporations’ share prices, the critical question will be whether this alliance has any long-term impact, directly or indirectly, on alleviating the environmental burdens on the planet caused by the agriculture industry’s hyper-focus on animal-meat production.

In January 2021, Microsoft reported nearly $43.1 billion in revenue, which amounts to a 17% increase over its last quarter. This beat analyst expectations of a 10% increase and was driven by an increasing demand for cloud services, Windows licenses, and Xbox gaming during the pandemic. However, this success did not occur overnight. Microsoft’s boom was set in motion in 2014, when Satya Nadella first took over the company from Steve Ballmer and pledged to transform Microsoft from a company focused on Windows and personal computing to a diversified services and devices company more akin to Google than to Apple. At the time, Microsoft’s Nasdaq shares were hovering around $40, and Redmond was still reeling from a shaky Windows 8 launch and disappointing sales of Windows Phones. Under Ballmer, Microsoft had doubled down on adapting Windows to all devices and even selling Microsoft-branded hardware, such as Surface tablets and Nokia phones. However, its approach backfired as enterprise and home customers found Windows 8’s touch-centric features and controversial removal of core features (such as the Start Menu) confusing to navigate. Mobile customers also continued to gravitate to Apple’s iOS and Google’s Android because of their more robust ecosystem of apps, services, and accessories.

To say that Nadella fundamentally reshaped Microsoft’s strategy is an understatement. In his first five years, he replaced Redmond’s sputtering Windows-centric business with a diversified focus on cloud services that would allow Microsoft to survive the mobile industry’s eventual elimination of the Windows operating system monopoly. To that end, he doubled down on engineering investments in Microsoft’s Office platform and improved the user interface and cloud accessibility of documents and storage. He added classroom and team management software to Office’s portfolio and adopted a platform-agnostic model to ensure Android, iOS, and macOS users equal access to Microsoft’s productivity applications. And Nadella made a bet on Microsoft’s most important product of the 2010s: its Azure cloud platform. By directing money into server technology innovation, Microsoft morphed Azure from a side project into a behemoth cloud platform that could host content for billions of devices and websites. Azure is now second only to Amazon Web Services in users. And as more services from fitness classes to schools move online in the pandemic, Azure and Office 365 now account for $16.7 billion in revenue for Microsoft—nearly 34% higher than the earlier year.

Nadella’s bet on a diversified Microsoft has also paid dividends for its other core businesses such as Windows, Xbox, and Surface. By listening to what its core enterprise and enthusiast customers wanted instead of forcing user-unfriendly designs, Microsoft fixed most of Windows 8’s shortcomings with Windows 10, which saw the reintroduction of the Start Menu, streamlined settings and notifications panels, and frequent updates that transformed Windows into more of a service than an operating system. A similar mindset focused on user feedback aided Microsoft in retooling new versions of its Xbox and Surface tablets with better performance per price. As a result, Xbox revenues climbed 14% to $15.1 billion in early 2021 and Surface revenue increased 37% to $1.5 billion in 2020.

Redmond’s shift away from a Windows-centric business to a diversified cloud-focused model has resulted in record growth and decisive success, as Microsoft’s shares are now trading well above $200. With Nadella at the helm and more businesses turning to cloud platforms to conduct business amid a global pandemic, Microsoft’s wise decisions over the past decade will continue to set the foundation for its renaissance.

2021 Valentine’s Day celebrations are not immune to the permeating effects of the pandemic, especially in light of the Covid-19 surge in romance scams. Fraudsters are taking advantage of the heightened use of dating apps and the legitimate barriers to in-person dating in order to carry out their scams. Scammers develop a virtual relationship, strengthen the connection while unsuspiciously avoiding in-person meetups, and eventually make credible requests for money before disappearing. The conditions created by the pandemic “are ripe for such fraud.”

As people spend more time online, feel more reliant on dating apps, and have more convincing reasons for monetary requests (e.g., medical bills), romance fraud has flourished. The Federal Trade Commission reports that consumers lost over $300 million to romance scams in 2020, which represents a stark increase from the year prior (51%).

The FBI is warning the public to be on high alert of these prolific scams in the wake of Valentine’s Day, cautioning: “never send money to anyone you don’t know personally.” Further, the FTC is emphasizing the crucial role that companies play in protecting their consumers. It is the responsibility of “companies bound by anti-money-laundering rules to report suspicious activity,” and to adjust systems to adapt to the new tactics employed by fraudsters.

One such example of company intervention is Western Union Co. To remedy criminal and civil charges brought against the money-transfer company—for failing to effectively police customers who were using its services to engage in fraud—Western Union has significantly improved its monitoring technology, leading to a stark decrease in reported romance scams.

It is crucial for companies to stay ahead of fraudsters’ evolving tactics through data analytics tools and other technological safeguards, however Western Union’s competitors also highlight the need for customer outreach and education. Not only has the pandemic created an increased reliance on, and normalcy around, online relationships, but it has also increased people’s “loneliness, isolation, and vulnerability.” Companies must recognize that people tend to be gullible in the face of loneliness and opportunity for romance and promptly inform victims of a potential for fraud to which they might be blind.

Regulators warn that scammers will be especially active as people are looking for love this Valentine’s Day. A study warns that the implications of such scams is far greater than a one-time monetary hit: the fraud usually continues after the original scam, and importantly, the emotional harm to the victim can be more harmful than the monetary loss.

Both companies and consumers need to be on high alert in proximity to Valentine’s Day, as the holiday provides scammers with yet another opportunity to strike. Shakespeare might tell us “love is blind,” but this year, we must all keep our eyes wide open to the reality of scammers.