Siegel provides only very brief summaries of the kind of “public accusation” these
insiders suffered in Mexico. It remains unclear whether the accusations were based on criminal, tax,
or securities law, or even whether the accused ended up being punished by the alleged illegal practices.
In at least five of his ten reported cases, the accused was suing the government to recover damages
suffered, was acquitted or had her charges dismissed. It is also unclear what the legal results were for
the minority shareholders who lost value and took action against the companies (according to his table
3). Overall, one cannot determine from Siegel’s presented data if the legal mechanisms and results of
Mexican public and/or private enforcement were ultimately more effective than in the United States.
84 See Kenneth Rapoza, CFO Who Laid Low Brazil's Sadia: Blame It on Lehman, Dow Jones
Newswires (Apr. 17, 2009): “Sadia is Brazil's sixth-largest exporter. As a brand, it is the equivalent of
a Purdue Farms Inc. As an investment, Sadia's New York-traded shares have collapsed 72% since
Sept. 25 [2008], making it one of Brazil's biggest victims of the financial crisis