As Robert Anello wrote in "Forbes" in 2014, "Analysis of the corporate "mens rea" is, by definition, contrived and one with which federal courts have struggled." In the US, there is a three-way circuit split, as the Fifth Circuit and the Eleventh Circuit apply "respondeat superior", the Second Circuit and the Seventh Circuit and the Ninth Circuit apply instead a concept of "collective knowledge", and the Sixth Circuit rejects the "respondeat superior" and collective knowledge approaches and applies its own – third – approach because in its view neither the "respondeat superior" approach nor the collective knowledge approach is ideal or effectuates the purpose of securities fraud laws.